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Pocomoke City - First Amended Complaint","","First Amended Complaint filed in the U.S. District Court for the District of Maryland by Franklin Savage, Kelvin Sewell, and Lynell Green against Pocomoke City and related officials. The pleading alleges pervasive race-based discrimination and retaliation against three African American police officers, including hostile work environment conduct, threats, humiliation, false accusations, and demotions. It further alleges employment actions tied to the filing of EEOC complaints, including termination and a resignation prompted by work-environment health concerns. 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Market St. Room 1103  \nSnow Hill, MD 21863  \nREGGIE T. MASON,  \nin his official capacity as Worcester County Sheriff  \n1 West Market Street, Room 1001  \nSnow Hill, MD 21863  \nCounty of Residence: Worcester  \nServe on: Jason Levine  \nAssistant Attorney General  \nMaryland State Treasurer’s Office  \n80 Calvert Street, 4th Floor Annapolis, MD 21401  \nFIRST AMENDED COMPLAINT FOR DECLARATORY RELIEF, INJUNCTIVE RELIEF, DAMAGES, AND ATTORNEYS’ FEES  \nCivil Action No. 1:16-cv-00201-JFM  \nJury Trial Demand  \nCase 1:16-cv-00201-JFM Document 23 Filed 03/16/16 Page 2 of 57  \nRUSSELL BLAKE,  \nin his individual capacity only  \nERNIE CROFOOT,  \nindividually, and in his official capacity as Pocomoke City Manager  \nBRUCE MORRISON,  \nindividually, and in his official capacity as Pocomoke City Mayor  \nBEAU OGLESBY,  \nin his individual capacity as the Worcester County State’s Attorney  \nNATHANIEL PASSWATERS, individually, and in his official capacity as a Worcester County Sheriff’s Office Sergeant  \nBROOKS PHILLIPS,  \nindividually, and in his official capacity as a Department of Maryland State Police Corporal  \nDALE SMACK,  \nindividually, and in his official capacity as a Worcester County Sheriff’s Office Deputy  \nRODNEY WELLS,  \nindividually, and in his official capacity as a Worcester County Sheriff’s Office Corporal  \nand PATRICIA DONALDSON, individually, and in her official capacity as a Department of Maryland State Police Sergeant  \nDefendants.  \nINTRODUCTION  \n1. This is one of the saddest and most shocking cases this Court is likely to address. Three African American police officers, working for Pocomoke City, Maryland, experienced racial discrimination in employment and retaliation for the exercise of their federal civil rights in  \nCase 1:16-cv-00201-JFM Document 23 Filed 03/16/16 Page 3 of 57  \na manner that most Americans would have believed unthinkable in the second decade of the Twenty-First Century. While Pocomoke City bills itself as the “Friendliest Town on the Eastern Shore,” its law enforcement community, including police officers and elected officials from the Pocomoke City Police Department, the Department of Maryland State Police, the Worcester County Sheriff’s Office, and, most disappointingly, the Worcester County State’s Attorney’s Office, acted more in the vein of “Jim Crow.”  \n2. Three model police officers, including the first African American chief of police in Pocomoke City and the first and only African American detective assigned to the local narcotics task force, were mocked, threatened, demeaned, demoted, punished, falsely accused of misconduct, ostracized, and humiliated because of their race. Ultimately, two of the Plaintiffs here, Franklin Savage (“Officer Savage”) and Kelvin Sewell (“Chief Sewell”), were fired by Pocomoke City in obvious retaliation for their filing of United States Equal Employment Opportunity Commission (“EEOC”) complaints. The third officer, Lynell Green (“Lieutenant Green”), resigned from the Pocomoke City Police Department due to health concerns arising from his work environment. The intervention of this Court is vitally necessary to make clear to some members of the law enforcement community on the Eastern Shore that this blatant disregard of federal constitutional and statutory rights will not be tolerated.  \n3. The use of the word “nigger” long ago ceased to be tolerated in any American workplace. So, too, did other forms of racial mockery, epithets, threats, humiliation, and discrimination based on race in the terms of employme","cbCaigJ9OUQm6UD3","https://ap.wps.com/l/cbCaigJ9OUQm6UD3","pdf",244390,57,"English","# Introduction\n## Plaintiffs and alleged discrimination\n## Employment actions and retaliation claims\n## Racial harassment details\n## Supervisory conduct\n## Reporting and alleged career consequences","[{\"question\":\"Who are the plaintiffs and who are the defendants in the First Amended Complaint?\",\"answer\":\"The plaintiffs are Franklin Savage, Kelvin Sewell, and Lynell Green. The defendants include Pocomoke City and multiple officials, including the county sheriff and related law enforcement leaders.\"},{\"question\":\"What wrongdoing does the complaint allege?\",\"answer\":\"The complaint alleges race-based employment discrimination and retaliation, including a hostile work environment, threats, humiliation, demotions, false misconduct accusations, and other discriminatory conduct.\"},{\"question\":\"How does the complaint connect the retaliation to EEOC activity?\",\"answer\":\"The complaint states that two plaintiffs, Franklin Savage and Kelvin Sewell, were fired in obvious retaliation for filing EEOC complaints. It also describes adverse career consequences after reporting internally and leaving a joint task force.\"}]","Savage et al v. Pocomoke City - First Amended Complaint | PDF",20]