An institutional tradition of brutal hazing was tolerated, and even encouraged, by administrators and staff at South Carolina's well known and influential Camden Military Academy, according to the allegations of a federal lawsuit filed in U.S. District Court in Columbia on March 23, 2012. Lead counsel Marguerite S. Willis, along with William S. Tetterton and R. Keegan Federal Jr., represent a former student who enrolled at Camden when he was 13 and claims to have been treated in the school's infirmary 19 times in four months of constant harrassment, repeated beatings and, ultimately, forcible sodomy and rape.
An institutional tradition of brutal hazing was tolerated, and even encouraged, by administrators and staff at South Carolina's well known and influential Camden Military Academy, according to the allegations of a federal lawsuit filed in U.S. District Court in Columbia on March 23, 2012. Lead counsel Marguerite S. Willis, along with William S. Tetterton and R. Keegan Federal Jr., represent a former student who enrolled at Camden when he was 13 and claims to have been treated in the school's infirmary 19 times in four months of constant harrassment, repeated beatings and, ultimately, forcible sodomy and rape.
An institutional tradition of brutal hazing was tolerated, and even encouraged, by administrators and staff at South Carolina's well known and influential Camden Military Academy, according to the allegations of a federal lawsuit filed in U.S. District Court in Columbia on March 23, 2012. Lead counsel Marguerite S. Willis, along with William S. Tetterton and R. Keegan Federal Jr., represent a former student who enrolled at Camden when he was 13 and claims to have been treated in the school's infirmary 19 times in four months of constant harrassment, repeated beatings and, ultimately, forcible sodomy and rape.
3:12-cv-00846-JFA Date Filed 03/23/12 Entry Number 1 Page 1 of 28
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF SOUTH CAROLINA
COLUMBIA DIVISION
Shon D. Cameron and Laura A. Cameron,
on behalf of their minor child, JBC, Civil Action No; _3:12-¢v-00846-JFA
Plaintiffs,
vs.
Camden Military Academy; Eric Boland,
individually and as an employee of
Camden Military Academy; C.H.
‘Armstrong, individually and as an COMPLAINT
employee of Camden Military Academy;
Vertis Wilder, individually and as an JURY TRIAL OEMANDED),
employee of Camden Military Academy;
Denise Miles, individually and as an
employee of Camden Military Academy;
and John Richard, individually and as an
employee of Camden Military Academy,
Defendants.
Plaintiffs, Shon D. Cameron and Laura A. Cameron, as guardians of JBC in his
Complaint against Defendants, allege as follows:
1. Plaintiffs, Shon D. Cameron and Laura A. Cameron, parents and
guardians of JBC (hereinafter “JBC” or “JBC"), are citizens and residents of the State of
Georgia.
2, JBC, a sixteen (16) year old child, is a citizen and resident of the State of
Georgia3:12-cv-00846-JFA Date Filed 03/23/12 Entry Number 1 Page 2 of 28
3. Defendant Camden Military Academy (hereinafter ‘CMA’) is a corporation
duly organized and existing under the laws of the State of South Carolina with its
principal offices and facilities located in Camden, South Carolina,
4, Erie Boland is a citizen and resident of South Carolina who was employed
as Headmaster by Camden Military Academy during the period from 2008-2009. At
some or all of the relevant times herein, Defendant Boland was known as “Colonel
Boland” at CMA. Defendant Boland is currently the Chief Executive Officer and Chief
Financial Officer of Camden Military Academy. Upon information and belief, Defendant
Boland is responsible for the overall operations at CMA. Plaintiffs sue Colonel Boland
as both an employee of CMA and in his individual capacity.
5. C.H. Armstrong is a citizen and resident of South Carolina who was
employed as Commandant by Camden Military Academy during the period from 2008-
2009. At some or all of the relevant times herein, Defendant Armstrong was known as
“LTC Armstrong” at CMA. Upon information and belief, Defendant Armstrong is
responsible for the management of staff and cadets at CMA. Defendant Armstrong is
the supervisor of the "Tactical Officers” (TAC) who are responsible for the barracks in
which cadets are housed. Defendant Armstrong also oversees cadet issues such as
academic absences and leave requests. Plaintiffs sue LTC Armstrong as both an
employee of CMA and in his individual capacity.
6. Vertis Wilder is a citizen and resident of South Carolina who was
employed by Camden Military Academy during the period from 2008-2009. At some or
all of the relevant times herein, Defendant Wilder was known as “Sergeant Major
Wilder” at CMA. Upon information and belief, Defendant Wilder is the TAC officer3:12-cv-00846-JFA Date Filed 03/23/12 EntryNumber1 Page 3 of 28
responsible for the care, custody and control of cadets assigned to the “Delta” (D)
Company, the company in which JBC was housed. Plaintiffs sue Sergeant Major Wilder
as both an employee of CMA and in his individual capacity.
7. Denise Miles is a citizen and resident of South Carolina who was
employed as a nurse by Camden Military Academy during the period from 2008-2009.
At some or all of the relevant times herein, Defendant Miles was known as "Nurse
Denise” at CMA. Plaintiffs sue Nurse Denise as both an employee of CMA and in her
individual capacity.
8. John Richard is a citizen and resident of South Carolina who was
employed as a wrestling coach by Camden Military Academy during the period from
2008-2009. At some or all of the relevant times herein, Defendant Richard was known
as ‘Captain Richard" at CMA. Plaintiffs sue Captain Richard as both an employee of
CMA and in his individual capacity.
9. Although not named as defendants herein, Cadets Cosia, Kelly, Meadows,
Settles, Tappin and White all attended Camden Military Academy during the time of
JBC's enrollment and all participated in the acts of assault and battery alleged herein
JURISDICTION AND VENUE
40. This Court has jurisdiction over Plaintiffs’ claims pursuant to 28 U.S.C.
1332
14, The amount in controversy, without interest and costs, exceeds the sum
$75,000.
42. Venue is proper in this jurisdictional district pursuant to 28 U.S.C.
§1391(0).