Romulus Police Chief Dickerson lawsuit.pdf - MLive.com

2:13-cv-10771-JAC-MKM Doc # 1 Filed 02/25/13 Pg 17 of 18 Pg ID 17COUNT III:VIOLATION OF MICHIGAN PUBLIC POLICY102. Plaintiff re-alleges word for word paragraphs 1 through 101.103. Plaintiff refused to commit a crime in the course of his employment, to wit: todestroy material evidence of an officer assaulting a handcuffed prisoner asinstructed by Defendant Chief Dickerson.104. Michigan public policy provides that an employer may not retaliate or take anyadverse employment action against an employee who refuses to commit a crimein the course of his employment.105. Defendant City of Romulus d/b/a City of Romulus Police Department eliminatedPlaintiff’s position in the Detective Bureau and took other adverse employmentaction against him because he refused to commit a crime in the course of hisemployment, to wit: he refused to conspire in a cover-up and destroy evidence ofcriminal conduct by a co-employee as instructed by Defendant Chief Dickerson.(See, 81-84.)106. As a direct and proximate result of Defendants’ violation of Michigan publicpolicy, Plaintiff suffered economic and non-economic injuries including, but notlimited to, lost wages, loss of professional opportunities, emotional distress,anxiety, depression, fear and other compensable injuries.ACCORDINGLY, Plaintiff asks this Court to enter judgment in Plaintiff’s favor inexcess of the jurisdictional limit of the Court, including attorney’s fees, costs and interest, andprovide Plaintiff with all legal and equitable relief to which he may be entitled, includinginjunctive relief against any further acts of retaliation by Defendants and reinstatement.