Romulus Police Chief Dickerson lawsuit.pdf - MLive.com

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2:13-cv-10771-JAC-MKM Doc # 1 Filed 02/25/13 Pg 2 of 18 Pg ID 22. Plaintiff Kevin Ladach is a member of the City of Romulus Police Departmentand transacts business in Wayne County, Michigan which is located in thisDistrict.3. Defendant City of Romulus is a Michigan municipal corporation which operatesthe City of Romulus Police Department which transacts business in WayneCounty, Michigan and is located in this District.4. Defendant Robert Dickerson is an employee of the City of Romulus d/b/a City ofRomulus Police Department and the Chief of Police for the City of RomulusPolice Department which transacts business in Wayne County, Michigan and islocated in this District. Defendant Dickerson is being sued in his official andindividual capacity.5. Defendant Derran Shelby is an employee of the City of Romulus d/b/a City ofRomulus Police Department and a Captain of the City of Romulus PoliceDepartment which transacts business in Wayne County, Michigan and is locatedin this District. Defendant Shelby is being sued in his official and individualcapacity.6. When the events alleged in this Complaint occurred, the individual Defendantswere violating Plaintiff’s clearly established constitutional rights and their actionswere clearly unreasonable. As such, the individual Defendants are not entitled tothe defense of qualified immunity.7. Defendant City of Romulus d/b/a City of Romulus Police Department cannotavail itself of governmental immunity pursuant to its intentional actions takenagainst Plaintiff as such are intentional torts and immunity against said
2:13-cv-10771-JAC-MKM Doc # 1 Filed 02/25/13 Pg 3 of 18 Pg ID 3governmental agency have been waived pursuant to the Whistleblower ProtectionAct, being MCL 15.361. In addition, sovereign immunity does not apply tomunicipalities such as the City of Romulus d/b/a City of Romulus PoliceDepartment.8. The individually named Defendants are each being sued in their individualcapacity as well as in their official capacities.9. The acts, transactions and events which give rise to this action all occurred in theCity of Romulus, Wayne County, Michigan which is located in this District.10. This Court has jurisdiction over Plaintiff’s federal and state claims pursuant to 42USC § 1983, 28 USC § 1331, 28 USC § 1367 and the amount in controversyexceeds the jurisdictional limits of this court, exclusive of costs, fees and interest.COMMON FACTUAL ALLEGATIONS11. In September of 1999, Plaintiff was hired by Defendant City of Romulus d/b/aCity of Romulus Police Department as a civilian dispatcher.12. Sometime in 2003, Defendant City of Romulus d/b/a City of Romulus PoliceDepartment sponsored Plaintiff’s entry into the Police Academy.13. From 2003 through February 2009, Plaintiff worked as a patrolman on road patrolfor Defendant City of Romulus d/b/a City of Romulus Police Department.14. Sometime in 2009, due to Plaintiff’s exemplary performance and qualifications,he was assigned to the Detective Bureau of Defendant City of Romulus d/b/a Cityof Romulus Police Department.15. Sometime in July of 2011, due to Plaintiff’s exemplary performance andqualifications, he was promoted to the position of Sergeant.
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Romulus Police Chief Dickerson lawsuit.pdf - MLive.com

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