Case 3:20-cv-00785-DPJ-FKB Document1 Filed 12/07/20 Page 1 of 42 IN THE UNITED STATES DISTRICT COURT. FOR THE SOUTHERN DISTRICT OF MISSISSIPPT NORTHERN DIVISION MELVIN WILLIAMS, RHONDA DANIELS, PLAINTIFFS GARRY ARTHUR, MAMLE BARRETT, ALMEIA BOLDEN, -RODNEY DANIELS, DEJON ARTBERBERRY, RAKASHA ADAMS, CRAIG CROWLEY, KEITH FREEMAN, TAMMY HEARD, MICHAEL PUGH, PAMELA RIGBY, VANESSA JOHNSON, CANDICE INGRAM, LATEEF SKINNER, RIZIRIO CAMEL, MIRON SMITH, TERRANCE TILLER, ROBERT WATTS and UCONDA CARTER V5. CIVIL CAUSE NO. -V-785-DP SFB: THE CITY OF JACKSON, JACKSON POLICE DEPARTMENT, DEFENDANTS MAYOR CHOKWE ANTAR LUMUMBA, in his capacity as mayor and individually, CHIEF JAMES DAVIS individually and \n bis professional capacity, DEPUTY CHIEF DERIC HEARNS individually and us deputy chief uf police, E, BRADLEY LUMUMBA alias (HONDO), individually, und his cupachy with the City of Jackson, VINCENT GRIZZELL individually, und In his professional eapacity with the City of Jackson Defendants John Doe 1-5 Defendant John Doe Company 1-5 COMPLAINT (ury Demanded) COMES NOW, Plaintifis Melvin Williams, Rhonda Daniels, Gary Arhur, Mamie Barret. Almeia Bolden, Rodney Daniels. DeJon Ariberberry Rakuisha Adams, Crig Crowley, Kelth Freeman, Tantiny Heard, Michael Pugh, Fameta Rigby, Vanessa Johnson, Candlige Ingram, Lateef Skinner, Miron Smith, “Terrance Tiller,Case 3:20-cv-00785-DPJ-FKB Document i Filed 12/07/20 Page 2 of 42 Rizerio Camel, Ucomna Carter. and Robert Watts by and through their attorney of record and files this complaint against Defendants The City of Jackson, Mayor Chowke Antar [.umumba in his professional capacity-as the mayor-and individually, Chief James Davis professional and individually, Deputy Chief Detic Hearns in his professional capacity and individually, E. Beadiey Lumumba alia (HONDO) in is professional capacity end individually, Deputy Chief Vincent Grizzell in his professional and individual ewpacity for the following: violation of each Plaintiff's Ist. Sth and Mth U.S. Constitutional Amendments Rights, Title 42 of the United States Code, Section 1983 42 U,S.C, Section 1983, Tile VIL of the Civil Rights Act of 1964, Sex discrimination. race discrimination, sexist discrimitiation (gay tights), and STATE CLATMS OF: mentul anguish, body injuries, Fraud, Breach of fiduciary duties \o employees, misrepresentation, misuse of legal proceedings, joint tortlBasors, striet liability, negligent hiring, negligent retention, negligent supervising, intentional infliction of emotional distress, negligent infliction of emotional distress, brach of contract, individually and conspizacy of misappropriation of City's finds that were eaumarked to cach Plaintiff and others, misuse of state funds thitt belong to Plaintiffs, Intimidation, bullying, and striet liability for endangerment ul’ each officer fives by not having enough officers on duty ut any time endangering each Pluimitf’s life by not giving them s dated bullet pronf vest (Defendants have just revently this year provided bullet proof vest for cach Plaintill, but for years Plaintiff's vest were expired exposing them to imminent harm und severe mental distress), As such, Plaind ff will'show this honorable Court te wit: 2Case 3:20-cv-00785-DPJ-FKB Document i Filed 12/07/20 Page 3 of 42 JURISDICTION AND VENUE This matter is actionable under the United ‘States Constitutional First, Filth and Fourteenth Amendment Rights, Title 42 of the United States Code. Section 1983 42 vu Section 1983, ‘Ville VIT of the Civil Rights Act of 1964, wid this court has supplemental jurisdiction aver the state claims under 28 U.S.C. 1367, Venue is proper because there federa] questions asserted by PlaintiN's und Defendants ure located in the jurisdiction ef the Souther District of Mississippi Northern Division, F > REMEDIES Plaintiffs claiming discrimination of sex, race, color, retaliation and disability EEOC right to-sue letters ure attached hereto as exhibit A. TION OF TH: ODE, a Plaintiffs filed the required notice of Intent to sue with the Chiy of Jackson Clerk's office on July 14,2020, Hereto attached as exhibit B. Y STO THE COMPLAINT 1. Plaintiff Melvin Williams resides in Jackson, Mississippi Hinds County, 2, Plaintily Rhonda Daniels resitles in Jackson, Mississippi Hinds County 3. Plaintii’ Garry Arthur Daniels resides in Jackson, Mississippi Hinds Coury, 4, Plaintill’ Mamie Baxrewt resides in Madison, Mississippi 5, PlaiitiffAtetis Bolien Fesides in Jackson, Mississippi Hinds County, 6, Plaintill’ Rodney Daniels cesidesin Rankin County Mississippi, 7. Dlaimif¥ Defon Artberberry resides in Juckson, Mississippi Hinds County, 3Case 3:20-cv-00785-DPJ-FKB Document 1 Filed 12/07/20 Page 4 of 42 §, Plaintiff Rakasha Adams resides in Warren County Mississippi. 9. Plaintiff Craig Crowley resides in Jackson, Mississippi Hinds County, 10, Plaimil Keith Freeman resides in Hinds County Mississippi, 11, PlaintitY Tammy Heard resides in Rankin County Mississippi . 12, Plaintiff Michael Pugh resides in Jackson Mississippi. 13. Plaintiff Pamela Rigby resides in Madison, Mississippi, 14, Plaintif® Vanessa Johnson resides in Jackson Mississippi. 15, Pluintif¥ Candice tngram resides in Hinds County Mississippi. 16, Plaintiff Laieel Skinner resides in Jacksun, Mississippi, 17. Plaintiff Miron Smith resides in Jackson, Mississippi. 18, Plaintif¥ Terrance Tiler resides in Jackson, Mississippi, 19, Plaintit Robert Wants resides in Brooklyn New York, 20. Uconda Curter resides in Jackson Mississippi. 21, Defendant the City oF Jackson, and Jackson, Police Department is a municipality in the State of Mississippi and may be served with process through the City’s Clerk olfige locuted ate 219 South President Street, Jackson, MS 39201, Defendant Mayor Chokwe Antar Lumumba is a resident of Jackson, Mississippi, and out of respest of this Defendants privaey Plaintitls may be served with process Hhrough the Office of the Mayor 219 South President Street Jackson, Mississippi 39201,23s 26. 28. 29, 30, Case 3:20-cv-00785-DPJ-FKB Document Filed 12/07/20 Page 5 of 42 Defendant The City of Jackson Police Chief James Davis isa resident of Byram Mississippi Tlinds County and may be served with process wherever he may be found, . Defendant Derie Hears is-a resident of Porahonus Mississippi and may be served ith process wherever he may be found, Defendant E, Bradley Lumumba known alias (HUNDO) fs 4 Jackson, Mississippi Hinds County ai way be served with process wherever he aay be found, Defendant Vinceat Grizzell resides in Jackson, Missi pi-and may be served with process wherever he may be found, . Defendant John Doe identified pursuant (0 the FAR.CP, and at this time is believed 10 he persoufs] whom were employed as Deputy Chief of Police and/or employce of the City of Jackson Police Deparvnent during all relevant time to this complaint statue of limitations: Defendant John Doe Company are also identified pursuant to the FR.C.P, and al this time is believed lo be companies created by the Mayor Chowke Antar Lumumba, andor E. Bradley(ITond), a3 well as chief of Police James Davis. As such, Plainil! intends to identity said companies aj a different dime pursuant to the FRCP. In or tivound May 2020, each Plaintiffs avers that their protected right under the First u él States Constitutional Amendment right to fieedom of speech was breaeded by: all Defendants including Chief Jamies Davis seal exhibit © a letter demanding that 5Case 3:20-cv-00785-DPJ-FKB Document1 Filed 12/67/20 Page 6 of 42 public information a.secret tray even though Plaintitts (we servants of the public und the information that is demanded lo be kept secret is suppose to be what is knows as OPEN RECORDS to the public, Plaintiffs avers tut some of then were forced to:sign this letter and if they refused to sign Plaintiff Would be reprimanded or even terininated as an eniployee of The Cliy: of Jackson Police Department. Ax result, Plaintills ue concemed with this demand by the City of Jackyon, which Plaintiil’ comends violates their feedom of speech, especially since if there: is a call out for the police into the public that record is public information and not being transparent could hur the public at large. ‘To further injure some of the Plaintifis, Defendant James Davis, Deric Hears, Vincent Grizzle, E. Bradley Lumumba, and even the current Mayor, Cheowke Antar Lumumba caused, forced, made or even demanded that female oflicers Rekasha Adams, Amelia Bolden, and jail detention officer Ucona Carter submit to & Polygraph ‘fest, “Lie Detector Test," ( Plaintiffs avers that being forced to submit to a Polygraply test violated the City of Jackson's General Order and the same test was not even performed by a City of Juckson employee us required in the General Orders, Please see exhibit D the General Orders as prescribed in writing, G.0,200-8 TI (A)() (co). Plaintiffs avers that the shock, humiliation and embarrassmignt of being foreed and treated differently than their male co-vificers Has to this date caused mental anguish, and all of this just 10 see if either of them gave the loeal news anchors the “mug shot,” of police officer Mark Coleman whom) upon intormation and belie? was 6Case 3:20-cv-00785-DPJ-FKB Document Filed 12/07/20 Page 7 of 42 in fact arrested. These female police officers avers that they were picked out and picked on by Jackson Police Chief Jumes Davis, chief Derle Mearns, Deputy chiet’ Vincent. Grizzell, the City of Jacksoa Mayor Lumumba's driver/body guard E. Pradiey(llondo) and even the Mayer Cheowke Antar Lumumba siniply because they are females, These women were threatened with immediate termination and reprimands, as well us called into the Internal Affairs division of Jackson Police Department and questioned about information being leaked to the news anchors and the public abom Oflicer Mark Coleman’s arrest in carly Spring of 2020, Plaintiffs avers that it is regardless of w police oflicer or not, once u party is arrested the matter becomes public information, However. these female Plaintiffs contend that they were harqssed und humiliated before the mate officers in their respective positions all because il appears that Chie!’ James Davis, Deputy Chief Vincent Grizzell and E.Bradley(Hondo),whom Plaintilis contend is not @ sworn certified police officer, instead the Mayors relittive (See the last name) and the Mayor's personal bodyguard on the tax payers dollars for the sante, Plaintills contend thet HONDO, through the Mayor is found throughout (he causes in this lawsuit giving directions to certified Plaintits by abused authorities of Chic James Davis and Deputy Chief Vincent Grizell, as well as even Deputy Chief Deric Heams. Plaintiffs contend that sll of these" Defendants were/are moving-al the Mayor's command demanding that ong, if noball of these females leaked the photo of olfiver Mark Coleman to the public and therefore must be terminated of reprimanded for Umit reason, Plaintiffs avers that 73l, Case 3:20-cv-00785-DPJ-FKB Document1 Filed 12/07/20. Page 8 of 42 Mayor Cheowke Anur Lumumba during his eampaiga to run fur mayor of the Clty of Jackson, sware te the public that he/his administration would be transparent with information especially us it related to the City of Juckson Police, However, Mayor Lumumba beached that proniise a§ shown through out this kuvsuit, Also, upon information and belief Plaintiffs assert that officer Mark Coleman and Chie? James Davis were good Ifiends at the time of Mark Colemun's arrest and perhaps Chief’ James Davis was motivated by this fact in his elforis to harass these Women police officers under his authority, Especially since Internal Affnirs detective told all (3) Plaintifis, while being questioned about officer Coleman's Ieak to the public, that the Chief; James Davis has issued this proceedings Of questioning and the polygraph test (Lie Dectector tesl), Plaintiffs contend that ( intemal Affairs of fuckson Police Department reports and ts under the direct authority of the Chi james Davis), Sadly, i¢ followed (hut Pisintif? Ueons Carter, the detention jail officer whom was one of the mar y person on duty-at the Cy of Jackson's jail the day that Officer Mark Colemun was arrested, ended up being the fall “gity,” for the blood huint of a woman, whon told the media and public about officer Mark Coleman's arrest, at least Chie James Davis. Please see exhibit E, the lnternal Affairs signed and executed by Chief James Davis termination letter to Plaintiff Ucone Carter, a detention jail officer whom was ane of the many on duty the-night that efficer Mark Coleman's arrest, out whom was bullied, harassed, trieked to tke u polygrdiph teil, retaliated, and fired 8Case 3:20-cv-00785-DPJ-FKB Document 1 Filed 12/07/20 Page 9 of 42 without warning by Chie! James Davis in or around September 2020, Furthermore, Plaintiff Ucona Carter will show the original termination letter from Chief James Davis where it appears that a committee recommend for Her to reeeive [30] days off but liquid while out wos placed over it and the words (erminated in it's place, Ax such, Plaintiff Carter damages inelude showing other male officers whom when accused of greater weighing mutters were not terminated end are still on JED officers foree {0 this date, 2. Last, Plaintiffs contend thut Chiel James Davis daily forces them to adhere t6 HES RELIGIOUS BELELEFS. Plaintifls furtier contend that Chief James Davis has violated their constitutional first amendment right to be free: from religion ia yovernment. Pluintifis point to the City af Jackson Policy and Procudure when it Gomes to wearing your uniform during religious events, and x showing. of uny religious symbol while and during your work hours. Plaintills contond that the poticy and procedures of the City of Jackson are not enforced where it is clear that Chic James Davis not aly is Goistantly shown in the media with his religion being the answer for the bigh number of homicides, but he actually forces the police officer tw. go lo certain churches ( eul w meal fur free, Plaintiffs that have refised to go to these serving food churches. are met with serious inquiry as to why they ere not supporting u chureh, Exhibit X, is where Chief James Davis while in uniform, and inhis office, with a bible as displayed(at least it looks like-a King James Bible) found having the audacity ty state for a wiitten record thay he tells his ofilcers to pray and abo Case 3:20-cv-00785-DPJ-FKB Document1 Filed 12/07/20 Page 10 of 42 other. Plaintiffs conlend, that they havea constitutional right nat to be fareed with any government religious belief and Plaintiffs ol¥er an on point example as found in law that the TEN COMMANDMENTS cannot be displayed on government property, then why is Chief Jumes Davis allowed to infringe on Plaintiffs religious rights with what he calls his religion, As such, it is a clear violation of all Plaintiffs Mirst Amendment right to be lice from James Davis improperly foreinig his religion beliets into Plaintiff, because Plaintiffs contend that he could not he serving their God with the (ype of conduct he has displayed in this lawsuit. . PLAINTIFFS CLAIM OF THE VIOLATION OF THE UNITED STATES IST, STH AND MTT] AMENDED CONSTITUTIONAL RIGHT TITLE VII of the 1964 Civil Rights Act , Plaintitls contend that ‘lite VII of the 1964 Civil Rights Act established the Equal Employment Opportuniiy Commission to administer and enforce the Civil Rights law at work. As such, each Mointil! in this case ayers that their United Sates Constitutional Right of Due Process was violated by all Defendants whem cach Plaindi? was not alforded war opportunity \o promotions of temporary sergeants and other promotional positions. Plaintiffs contend that the U.S, Sth and [4th Amendment holds in part; * that states (goverment) is forbidden from denying any person "life, liberty or property, without due process of law" oF to “deny to any: person within its jurisdiction the equal. protection of the laws.” By diteetly meutioning the rule of the stuies, the L4th Amendment expanded the protection of civil rights (0 all citizens within its jurisdiction, As such, Plaintiffs exhibit P, is the 10Case 3:20-cv-00785-DPJ-FKS Document1 Filed 12/07/20 Page 11 of 42 policy of Juckson Police Depariment policy and procedures for témporry Serzeint positions of which these Deferiains have negligently and recklessly hand picked over around [10] individuals as temporary sergeants all while the City of Jackson Policy holds that 2 temporary sergéaint_may be temperurily put into piace for no grewter than 120 days, these corporals have held the job position without allowing a fair change to all persons interested in the sume, nor testing for tie positions us required by JP's pilicy, fi fac (appears that Mayor Cheowke Antar Lumumba and Chief James Davis simply does not have the fimding to pay for more ollivers, yet alone properly move existing officets into (ested sergeunt positions. Moreover, the ily oF Jackson Police Department fimuncial position is being so mismanaged by Mayor Cheowke Anter Lumumba and Chief James Davis until Chief James Davis actually bus [2] swarn certified POLICEMEN WORKING AS AUTO E THE Cry”: E, (Plaintiffs avers between the Muyor paying o sergeant salary to his bodyguard, along with officers working ay auto mechanics could possibly be [3] more uniform officers on the strests of Juckson protesting und helping wo lower the crime, Plaintiffs avers thut surely if the City of Jeckson and its Police Department had the available money, then they would huve hired or contracted ou! REAL MECHANICS as the City once had, But instead, for the edt budget that the Chy Counsel approved, Mayor Cheowke:Antar_ Lumumba ain Chief James Davis ultempted to tool, trick, disguise or any other adjective that shows defrauding: the yoters of the City of Inckson, hy REDUCING THE SIZE OF "3 Case 3:20-cv-00785-DPI-FKB Document i Filed 12/07/20 Page 12 of 42 THE MUCH NEEDED MANPOWER OF POLICE OFFICER BY NEARLY APPROXIMATELY |75] MEN AND WOMEN IN ORDER TO HAVE THE VOTERS THINK THAT THEY REALLY DON'T NEED AS MANY OFFLCERS THAT WERE REQUIRED, However, upon information and belief there Were ivise councilmen whom asked the question during the budget hearing swith the Mayor, what's radlly going on with this decrease budget on staffing police ollicers as desired and required in the City of Jackson, Plaintiffs avers that such trickery simply is nol true, ‘The size of the of Jackson requires many more ollicers that hus been currently budgeted and ask that each and every reader of this complaitit Seek and demand the ruth about the same for if'no other reason, it protects the shortage of ofivers on the streets and possibly save citizens and officers lives. Even more egregious, these temporary sergeants are paid an ineréased salary as a (ested sergeant and that 1oo fs against the policy and procedures of Jackson Police Department, Please see exhibit F. a ON_AN Ol Plaintilis Amelia Roklew, Rekasha Adaiis, Rhonda Daniels, Mamie Barnett. and Pamela Rigby, Uvona Carter, and Cassandra ‘Thomas, Candice Ingram, Vanessa Johnson, nid Bertha Spann ure all female employees working for the City of Jackson Police Depariment under the authority of Chief James Davis, Deputy Chief Derie Hewms, Deputy Chief Vincent Grizale und Mayor Cheowke Antar Lumumba: Each of these female Police women, Plaintiffs, contend the fullowing are frets for each as 12Case 3:20-cv-00785-DPJ-FKB Document1 Filed 12/07/20 Page 13 of 42. claimed hereto; Detectives Rionda Daniels, und Pamela Rigby are female Police Detectives for the City of Jackson and was forced to work at the City’s Impotind Lot that might be over [50] acres in size and full of abandoned, repossessed vebicles, and others property. This City Inipound Lot, although upon information and belie? and during-all times of Plaintiffs clainis including through the year of 2018-2020 is under the budget of the City of Jackson's Puble Works Departinent, and NOT the Police Department. As such Pluintiffs contend that they de not understand why these Defendants are likely commingling the funds of two different Departments nor sre Plaintiff aware that the City Counsel is aware of the sume, . The City of Jackson Impound Lat has @ building Ioeated on the grounds of the Ampound Lot, but during all releyunt times to these claims whereby these wamen had to use the restroom, NO KEY was provided to the women so they were forced to use the restroom outside on the grass and rocks while acting as a night time security guard, Also, the women police officers, Plaintiffs, like several male Plaintif’s in this case is. found reporting the waste that was left to the:sueams and dangerous and ungafe conditions, including the sighting of snakes While being a night time seeutity guard in guarding the impound lot to Deputy Chie? Derle Hearns and Chief James Davis, but no relief was found for neither the males nor females. Plaintiff's exhibit A, ure pictures that shows u gllapse off what these ladies were guarding and Plaintiffs expressly complains that not only did they huve to guard the impound lot like security guards, hur the impound lot had NO LIGHTING. THEY WERE SHOT 1338. 8) 39, Case 3:20-cy-00785-DPJ-FK3 Document1 Filed 12/07/20 Page 14 of 42 h IN LADY 70 RELIEVE HERSELE, instead these female officers were treated as an animal and forced tu use the restroom outside, These female Plaintills avers that the hours-to guard this inipound lot usually was from 9:00 pan, until 5:00 aan, although the lime varied it was always late night until the next dawn morning, und equally: worst was the fact that chiel James Davis has at any given time ONEY {2] officers ta guard over approximately 50 ucrées of abandoned cars and others property. Plaintii avers that they don't know shy the City of Jackson would pay certified police officers 10 act like security guards, except for the City of Jackson likely did not have the money to hire security guurds or even contract the work of security guards to a security company, Plaintif? Rekasha Adams, Amelia Bolden, and Tammy Heard, Rhonda Daniels, Mamie Barreit, and Pamels- Rigby all submit to this court that they were not ireated ‘equally as the male officees by all Defendants und at all times relevant to this lawsuit specifically front 2018 to present. dn fact, Mayor Cheoivke Antar Lumumba even met with the Jacksen Police Officers, including these women regarding why the MORALE al the City of Jackson Polive Officers was extremely low, There the Mayor told the officer that he knew that the then Deputy Chief Tina Wallace (upoa infomation atid belief Wallace has singe retired), and James Davis lack of munagement skills over Tina Wallace was at iste, ‘There the Mayor promised 14Case.3:20-cv-00785:DPI-FKB Document1 Filed 12/07/20 Page 15 of 42 Maintifis that he was going to terminate Tina Walluce so thal de MORALE ofthe officers could improve. He did not, and the MORALE under Chief James Davis, Depuy Chief Derie Hearns; Depuly Chief Vineent Griaell and the Mayor's administration has agtuully gotten worst, at least as claimed by these Plaintifts. Additionally, upon information und belief, just last month during = meeting with certain City of Jackson Counsel members, Chie! Janes Davis was tald in open forum: by Plaintiff Rhonda Daniels that he was lying to the cvneilmen about the City of Jackson Pollee Department MORALE was good, in tact, it is believed that Rhonda Daniels came to speak behind Chief James Davis und stated to the City: of Jackson's councilmen “thitt man just lied to ya'll), Aya result, of believing and trusting-in the Mayor's promise to make the ladies work environment free from hostility and, these: women police olligers eurnestly believe thal the Mayor {s allowing the Chief of police and his deputies to negligently and recklessly inflict emotional distress onto them becatise they do nol treat Policewomen as they do Polleemen, Otherwise, Plaintiff's contend that surely the Mayor would not expect a woman 10 have to relieve herself like a wild animal outside in an open field, Surely the Mayor knew: or should have known that his Chief of police has female policewomen working under him and that if those females showed up for a miveting with the Mayor for hela with the hostile sexist, sexual. and racial discrimination environment that tie Mayor had. aduty to know ubout ivand to jmmedistely 4temedy the situation, but he has not,4 4 = Case 3:20-cv-00785-DPI-FKB Document1 Filed 12/07/20 Page16 of 42 Additionally, Plainti Rhonds Daniels, Tammy Heard, Mamie Barrette. und Pamela Rigby they are weared difiereitly due 16 tlisie protected U.S, Constitutional right of choosing and displaying their sexual orientation, Each of these Plaintiffs will show how they were individually tngeted by these Defendants beestise of their sexual orientation. Plaintifs attached the same facts as exhibit L. Even more egtegious to Ihese fikts i thal ollicer Cussimdra Thomas, the qualitied and the only female palicewomun seeking! sought to be a SWAT TEAM member, which was all male liom the yeu of 2018 to present was denied the opportunity to be apart of PD's ALL MALE SWAT TEAM, ‘The denial of this Plaintiff into the SWAT EEAM was so severe that she ended tip leaving JPD:in or around September 2020 to work for a dilfevent Police Department in another County in Mississippi In hopes of excelling tp the ranks fairly as mien, Please see exhibit J. }. Moreover, PlaintiiY Pumeis Rigby a white femule officer whom has now retired due lo a.number of raciel discrimination acts by Chief James Davis, Deputy Chief Derie Teams and duty Chief Vincent Grizzell, Plaintil was promoted to property erimes a8 an investigator With the rank of deteetive on January 5, 2015. PlaintifFavers that upon assignment she was one of Iwo white detectives assigned to the unit. This Plaintif¥ can document the number of felony arrest she-and submitted to the Hinds County DA'S olftee iin 2013-76 eases, 2016-98 cases, 201788 cases, 2018-170 cases, 2019=114 cases, and as of July 2020=41 cases, This Plaintiff eamplained to the gommrand staff that the black felloiv detectives were not being assigned the same 16Case 3:20-ev-00785-DPJ-FKB Document 1 Filed 12/07/20 Page 17 of 42 case load as she and that site felt like it was because she was a-white lesbian. Upon information and belief Chief Janes Davis allowed the supervisor whom gave out the gases each day to. g0 to lunch for hours at a time with the black detectives in the unit, leaving the majority of the case load in Rigby’ hand, Plaintiff complaiiied of this infair treatment all the way to Human resources but the matter was fot remedied. Instead, it yot worst. Mayor Cheowke Antar Lumumba held & meeting that Rigby antended whereby Rigby herself told the mayor that 4 black co-worker named Sharon Jordan has suid that she and the Mayor were good friends,(this go-worker und Plain Rigby had several near verbal fights in the department of which nothing was over done), until during the meeting Plaintiif Pomela Righy, in open meeting at the police neademy, even told Mayorthat Sharon Jordan says you and she are best of) friends and that even later, at the duration of the meeting. Sharon Jordan was seen huyging the nwayor to prove lier point, Still nothing was done about the Taeially indifference of the trentment of Rigby, Additionally, Plaintiff Rigby tells of how these had actors knew that during COVID-19 asergeant Obie Wells commanded her to assist u business burglary Victim whom had been shot in the butt and was bleeding oul and believed to have contacted COVID=19, Afler much texting and asking that she, due to her health not be placed in the proximity of the alleged burglary suspect. was demanded to ignore all the signs that there Was w problem and including a Hodges( a detention jail employee believed to be working in booking of suspects) would not receive the suspect because he was bleeding out and likely had 743, 44 Case 3:20-cv-00785-DPJ-FX8 Document1 Filed 12/07/20 Page 18 of 42 COVID-19, Bul instead of Chief James (avis intervening and finding the solution to the problem, it is belleved by Plaintiff that he pressured the sergeant to force Plaintill 10 handle the suspect whom could have died in her custody, Plonse see exhibit J, Next, Plaintiff Rekasha Adums was discriminated against when all Defendants conspired. to force her 10 quit biing 4 police woman, und, Inter ala, when they sent her to-work at the dog pound and treated her su badly that upen information and belief harassed her by culling and stuting to others that she was mentally ill fom a shooting incident of which she was found pot to have violaed any policy or procedure, In short, these Defendants have luirgeted this Plaintitf is such disgrace Uintil she has wWrillen over |5] memorandums to them to treat her-equally as they do the men police offivers whom had a shooting invident. Please see exhibit K, memorandums und picnires telling a portion of Adams horrilied experience as a demale officer with JPD. Then Plaintiff! Mamie Burret was one of maybe [2] crime scene investigators. PlaintllY complained time and again-about the severe need for help just te complete honiific crime scenes: and tho preserve evidence. Plaintiff uss woman was treated differently than men in that these Delendants did not provide Plaintiff Barrett with TOT WATER AND WATER PRESSURE vw process bloody and otherwise items containing bighizards material, no gloves were provided from these: Defendants instead, Plainti®' admits that she hed to beg wmbulance drivers far glaves just to do her job for the Jackson Police Department PlaintiiY Barreit us valuable as she is to 18Case 3:20-cv-00785-DPJ-FKB Documenti Filed 12/07/20 Page 19 of 42 aay crime scene was totally disrespected by Chief James Davis, Plaintiff contend tha, around Apri] or May 2020 she was culled into Chief Davit’s office in reference to the “Bully case." [lease see Exhibit M, this Plaintiff's own words of this incident. She was asked in front of Deputy chief Grizzell why she did not take a revolver; which was recorded by another officer on scene and tog it in with the evidence she recovered on the scene, Plaintill’ explained to him that the procedure is if'anolficer recovers something on scene we let thal eflicer log the evidence in and write arepor. Chief James Davis continued o ask Plaintiff Barrett the same question in-a different manner and Pluintitf states hit she explained (o Defendant Dayis that she actually lost eVidence in a murder trial by recovering a knife from a sergeant on a seéne who sloped a suspect fom destroying evidence and wrote a report to explain: chain of custody, However, Chifel Duvis stated to ber in from uf Deputy Chief Grizzle, “well ['m sorry your nut properly irained to do your job.” Plaintiff contends thet these no Defendants ‘eatsed her a great deal of embarrassment and emotional distress, Plaintiil’ contend that neither of those Defendants would have treated @ male or yet alone @ Black policeman like they treated her and she believes that such harassment treatment was due lo the fact that she is a syllteswoman, Plaintiff contend thut she told them that she works under harsh sometimes unbearable conditions, she fallows death, she looks into the eyes of the victims and hold thelr hands, she introduces herself to the blecding and stab wounded Individuals, sometimes someone's elilld, und due to all of this she has to make herself numb 1946. Case 3:20-cv-00785-DPJ-FKE Document 1 Filed 12/07/20 Page 20 of 42 to her surrounds and try al theend of the day to go home hoping she has done the job that she was trained to do for over IS years. Please see exhibit M. Last. Plaintiff Tammy TTeard believes that she is tented different from the policemen on the JPD because she is an open lesbian policewoman; ‘his police Wwomtin nequal treatment and harassment began as far back as 2014 when she was accused af nor spenking dircetly to w citizen whoin dialed 91 Land titer to have died from a bad detors conduct, ‘The issue with that aécusation is not only was it found that this police woman did not violate any rule with JPD, bur that since then she has been targeted and huruss to Ihe point that these Defendants not only terminated her and later gave her job back, but wetually made, forced demanded that she go all the way back-threugh police training ix arder to have her gun and badge:back. Plaintiff contend that even since 2017 that these Defendants have persistently wsitempted to reprimand ber and emberrass. humiliate her all because she is.a female and her sexual orientation is Identified asa lesbian. Please sce exhibit N, RACE DISCRIMINATION PlaintiffS Keith Freeman. Robert Watts, Mamie Barretl, Pamela Rigby, and Garry Arthur are all Caucasian of the European decent, But in the eyes of civil justice, whey are citizens of the United States of America and deemed to be entitled to the same rights and privileges ns uny other citizen. However, in this case, Freeman believes that he was treated differenily while working from 2017-2019, based on his race. 20a3, 4), Case 3:20-cv-00785-DPJ-FKB Document1 Filed 12/07/20 Page 21 of 42 Caucasian white policeman. As such. Freeman has attached exhibit O of actual events regarding bis élaims, Piaintif! Keith Freeman contend that Defendant James Davis allowed certain black police officers, such as Tina Wallace, to Set her/their detétred compuny time, but when Keith Freeman respectfully sought the sametreatment he was denied, Plaintiff Vreemun is adamant that he was treated differently for no other reason than that he is’ was at all times relevant from 2017 through 2019 while working for JPD. This Plaintii'alleges that he lost a large amount of money thut was é&mied pursuant 6 PP. policy and fules and that the money wes needed for the care of his gravely il] mother and family but was denied and never received the same due to his race as’ white policeman iy @ predominantly’ black police department in the City of Jackson. Plaintiffs all avers that such racism seems to be reversed RACE DISCRIMINATION but the tacts as revealed and furiher revealed will show that.xacism is the only logical reason af (hese Defendants bad conduct at all times relevant to this complaint. Plaintiff Freeman avers that he was tot able to sustain the ill treatment of Chief James Davis ta him because of’ his race, sa he was forced to retire due to the ill conduct of these Defendants, Nest, Plaintif?’ Garry Arthurs eauensian male JP poliveman since 2001 (o present. assert that during all relevunt times: to this-lawsuit from beyond 2017 until even present day he has been the rzet of ravial discrimination by these Defendants, Maintif® contend that these [efendunts forced Plaintiff to work in the Accident aCase 3:20-cv-00785-DPI-FKB Document i Filed 12/07/20 Page 22 of 42 Reconstruction Investigations all while knowing his disability of PTSD would be exacerbated and tightened by the-mere duties of the job as shown below. Plaintilt’ contend (hat he was diagnosed with PTSD due to the horrific deaths he-had seen as a reconstruction investigator and that these Defendants were made aware of the same but refused to relocate Plaintiff because of his race, he is: white police officer, Plaintii? furthes contend thor he was denied access to training school sinec it is recommended that every accident reconstruction investigator attend at least 40 hours of continued training, but these Defendants denied the same to Plaintiff, the white policeman, but did allow Michiel Outland to attend class and he is a black police officer. Moreover to express the kind of undue pressure from Defendants Plaintiff asserts that he believes he is being targeted by racially motivation by these Deleiidants becuse’ Plaintiff in November 2015 disagreed with the then chief of police, Lee Vance change an official report that Plaintiff wrote stating that un intoxicated pedestrian likely was xt fault in @ car accident that resulted in the death of the pedestrian, Plaintiil’ contend that he was forced to change a feport to:-save fice for the bad behavior of the ciel of police at that time and some of the other command staff, Plaintit? was told he was net-a team player and sines then Plaintiff has been treated differently because he is white and would nol go alone with the bud hick setors, Exhibit P specifically denotes the matters us complained by Plaimitf Garry Actus,Case 3:20-cy-00785-DPJ-FKB Document1 Filed 12/07/20 Page 23 of 42 50, Last, Robert Watts is another white officer whom was targeted by these Deféndanis in 2019. As u result, Warts was forced 10 seek eiuployment as a police afficer in another state because he simply could not deal with the racist wets of Chief James Davis and his stai¥ as complained in his own words attached hereto us exhibit Qa Plaintiff avers that attaching all the correspundence between Chief Janres Davis and the City of Jackson would likely better serve as evidence than have his attorney restate of the saine attachment, ‘There Plaintiff Watts: complains of clear attempts by Defendants as an attempl tw cover up racially sotivated acts againet Plait, 51. NEPOTISM BY MAYOR CHEOWKE ANTAR LUMUMBA WITH RELATIVE Uper information and belief, the Mayor's unele alias name; HONDO, not only is the mayoe’s bodyguard, although it appears the mayor his dheve wdditiowat hadveuaris and PlnintiNs strongly suggest that each of them likely has cily cell phones, gas cards far the at least (3/ different motareude thet follows and accomplish the Mayar when he i& moving about thought the City he says he cafes about, but is costing the tax payers at least un additional $200,000 in innceessary payroll and expenses, but Plaintiffs believe that this same relutive of Mayor Cheowke Antar Lumumba has a HINDS COUNTY CONTRACT WITH ANOTHER INDIVIDUAL WHOM IS ASSOCIATED WITH THE MAYOR, FOR THE ANKLE BRACING OF adjudicating inmates in Hinds County, Plaintiffs avers that the issue with this comiract is simple; i violates the City of Juckson 23Case'3:20-cy-00785-DPJ-FKB Document Filed 12/07/20 Page 24 of 42 policy and procedure NO. 3.5 and its following paragraphs as shown in exhibit S, NEPOTISM. 52. Plaintilts like so many others City of Jackson Employees work relentlessly to improve, assist, and maintain the City of Jackson even though they certainly know that Jackson is not taking care of their basic needs as provided in this Inwesuit, In fect, Some of those whem henefted fram Mayor Cheowke Amtar Lumumba’s Nepotisny and friend selection i one of his personal body guard Marcus Williams, ako Gout, Plaintiils contend that Mr. Williams is a good ofiicer and Plaintiffs do not seck 10 name the same as a Defendant , Plaintifls contend that Mr, Willisms is not only the Mayor Cheowke Aniar Lumumba's personal body guard( which appears to be EL of the 4] of the total of the Muyor’s body guards, but the Mayor also has a njotureade of at [vast [3] SUV'S and a Pick up truck for those personal body guards to follow the Mayor around in Jackson Mississippi), Plaintiffs vehemently believes that the total salwry aud expenses including the cost of fuel und upkeep on such an claborate life style by Mayor Cheowke Anta; Lumumbe ts estintated 10 be nearly a quarter of million dollars. Piaintiffs contend that such expense {ih the City that the Mayor is elected 40, Jackson, cannot possibly show cause for such a waste, Indeed perhaps the Mayor eould use [1] body guard, although past Mayor's like fanner Mayor Harvey Jahnson was known to drive himself eround in the city that he zan und Was elected ay mayor. 24Case 3:20-cv-00785-DPJ-FKB Document Filed 12/07/20 Page 25 of 42 53, Now back to this issue of Nepatism and the like, bodyguard Williams was not put inte the ACTING sergeant position ati) he became the mavor’s bodyguard , such a direct act of violating the City's policy {s not oaly wrong but dating in the face of all Plaintiff a9 claimed here, Plaintiffs contend that Mr, Williams is not a tested Sergent, and Mr. Williams actually gets all the overtime he desires. Pleas’ see exhibit G, a memorandunr from Defendant Derle Heams sisting all Policemen! Policeworen must eloek in atid ott, but the rule does not apply to the Mayor's bodyguards and escort team, . Moreover, Plaintifl's contend tut around or peur February or March 2020, Chiel’ Tames Davis ii his own special way decided 10 have all ACTING sergeants 1 re ¢ fo ACTIN sants position, cleurly failing to remember that his ani! Deputy Chet Vincent Gri and the Mayor had raised the Mayor's bodyguard. tg.an acting sergeant and such directive would affect the Mayor's bodyguard's pay aad title (again, uitder this administration neting sergeants are paid as though they are tested sorgennts), As 4 result, gach aud every person whom was already an ACTING sergeant was put right back in that some position causing even more mental anguish of Plaintitis, whom were never given-an equal opportunity te apply tor selected for the acting sergeants position, only Chief James Davis picks were put right back into aeting ails vider this administration, PIintifis avers thet elesrly here was never any attempt to fairly and properly interview other interested nor qualified officers nor did these Defendants even consider wny other officer whom 25Case 3:20-cv-00785-DPJ-FKS Document Filed 12/07/20 Page 26 of 42 hod interest in the tempor: ry position, and thereby violating each Pluinciff’s right to due: proces in government especially when the City of Jackson's own policy and procedures-had been violated as shown in exhibits F and G attached hereto. Plaintiffs avers tharto this date, il is not understood why these Defendants would continue to violate their righisto be treated equally as others whom were hand picked by Chief James Davis, » From 2017 through 2019 cach Plaintiil has been forced © change their nesmal scheduled day off from work into a day that the Mississippi State Fair paid the City of Jackson and its police deparnient certain earmarked monies for police officers to work it uniform, gun and badge. Upon information and belief these monies paid to Defendants, the City of Jackson and its police deparimentwere specilied for ONLY the security of people attending the Mississippi State Fair. However, to this date, NOT even one of these Plaintiffs have received any money for the extra hours worked which cach Plaintiff contend that the were tricked, forced, voereed, cared income converted, und deceived involtinturily ofa chunge ia their normal off day so that these Defendants could not have to pay them special pay: for working the Mississippi State Fair, and instead, Plaintiffs additional work would now be called their regular work hours, However, cach Plaintiff avers that prior to. this 26= Case 9:20-cv-00785-DPJ-FKB Document Filed 12/07/20 Page 27 of 42 administcalion any special events such as the Mississippi State Fair they were paid for working the same as extra pay, which exch Plaintiff avers Was supperiive of thelr extra income to their respective households, in short, Plaintifis had ineome stolen from them in a what uppears to be a switch and bail tactie by’ the City of Jackson, Mayor Cheowke Lumumba, and Chief James Davis. In fact, euch Plaintif avers that the said money due them at one time(lrom ether administrations) was paid in & separate check in order for the City to show accountabi for finds received trom the State of Mississippi. Moreover, each Plaintiff fisher contend that the SZ: r DE is mother event whereby the City of Jackson and these Defendants conspired (0 steal money and hide the use of the money from the parade, Indeed, cach Plaintift as shown in exhibit -R, was again told to switeh theirnormal days off and/or work in lieu of being pad for the St. Paddy Day Parade, Plaintiffs avers that the document is res isa locgultor, “Le the Defendants through the command staff actually is found telling Plaintiffs (hat they expected the crowds to be as great as 200,000, and that the organizer, Mr, Malcolm White would be esvarted in the punide by IPD motorcycle escort so that he could mise the money, Plaintiff further-avers that at last Jook, yesterday Malcolm White was not an employee of the City of Jackson und therefore, likely paid the City of Jackson for its resources. Additionally, apon information und belief the City of Jackson. und these Defendants: were paid for those resources (Plaintiffs as uniformed dutilidl officers) but gach Plaintiff did not recetve shy 27Case 3:20-cv-00785-DPJ-FKB Document1 Filed 12/07/20 Page 28 of 42 additional pay as was before Mayor Cheowke Antar Lumumba’s administration as well as the Defendants as claimed inv this luwauit, Plaintifis further assore thal not oaly were they not paid extra wages as-has been paid by previous administrations, but that the City of Jackson ceammunded by the current Mayor, Cheowke Antur Lumumba, Chief of police Jumes Davis, Deputy Chief Derie Mearns, and Deputy Chiof Vincent Grizzell conspired, procured, developed, sturted, made happen, or any olher adjective (hat promoies embezzling, misappropriating, ‘stealing, taking, nfsusing, translorming, converting and/or tuking from another for your persona! use, or misuse of fimds, teak monies that should have heen paid to each of these Plains bur instead. converted, cheated. stole, misused, misappropriated and/or took thu! same money without paying Pluintifis as extra pay abeve the normal course of work, }. Plaintiffs contend that the bad conduct claimed in the above paragraphs is nothing short of a conjured & panzi sehente. trick, beduzzlement, procurement of bad ideas, Russiun roulette, or just hustling of cach Plaintiff and their familiés by each Defendant. E ECON MISREPRESENTA‘ E . Plaintiff Melvin Williams, Deion Anterberry, Rodney Daniels and the other Plaintitls have complained (o these Defendants since 2018 that they DO NOT have enough people in auto burglary, Auto theft 12 detectives (ur this large urban city), Property Crime which consist of business and house bueglary in this large urban elty, 286 Case 3:20-cv-00785-DPJ-FKS Document1 Filed 12/07/20 Page 29 of 42 Aceldent reconstruction (2 investigators and one of which is Ptaintill! Gary Arthur whom has been out on medivil leave for several nionthy lo this dite], Ceme Seene Luvestigaror . Mamie Barrert which process crimes including enything ust reyuires finger prints, evidence left behind on u crime scene, and of course AOMICIDES, in this targe urban city), of which Plaintif’s avers that any person living within the City of Jackson to thiy date has 126 HOMICIDES to this date, Plaintiffs contend that such number is extremely high because for one thing, these Defendants tend to be only concerned about themselves and thelr friends and not the eitize n the Cty of Inekson, . As a result of this strange shorlage of policcmen/policewomen, detectives, and investigators, and even the civilisns whom does the inside work of JPD, Plaintifts contend thut they are NOT ONLY OVER WORKED, especially since upon information and belicf the City of Inekson simply does not have the budget not money to hire new police ollicers thereby causing cach Maintif¥ to work over 12 hours day. WHICH VIOLATES THEIR OWN POLICY, Please see exhibit $. the policy and procedures the City of Jackson GENERAL ORDED NO, 200-26, As a resull, cach Pluintif? in this lawsuit, because of the love and compassion of helping people and for the fove of the City they call home diligently jut in longer fours of work because they know thal these Defendants have been negligent and reckless with the Jackson Police Department. So cach Plaintiff goes home most days on eall which due to the increase number of OMICIDE and CRIMES their Job ever ends: 29Case 3:20-cv-00785-DPJ-FKB Document Filed 12/07/20 Page 30 of 42 However, It goes svithout redundancy that Plaintiils contend that these Defendants are dally ploying Russinn Roulette with euch Plaiatifts pay by switching the days off, and forcing cach Plaintiff to use the extra over-time hours 2s DEFERRED TIME AND/OR COMP-TIME. 6. . Pach Plaintiffs avers that the issue with forcing COMP TIME in liew of payment is thal the COMP TIME canno! be guaranteed pay If the Plaintiff separates from the Cily oF Jackson, In short, they just worked for nothing, Plaintiffs avers that stich policy and procedure violates the U.S, Labor Laws, As such; Defendants have Iveached their fiduciary duty to Plaintiffs us well as breached the implied, express and verbal contract by conspiring to deffaud and steal each Plaintiffs rightly earned income for them and their families. 63. Plaintiffs Melvin Williams, Dejon Arterberry, Rhonda Daniels, and Pamela Rigby all have duties that involve cases of crime as shown in the above paragraphs. These Pluintifis not only complained to these Delendams of being over worked(Plalntitls avers that each detective on a nidemal Week has al lewst 30 cages per week and by the time the nent Week arrives their are 30 additional cases and the first batch has not evea been resolved), but they also spevifically told these Defendants that thay cannot close nor properly work most cases assigned 10 thei because for reasons such as Plaintiffs will go do detective work fram 8:00 a.m, until $:00 p.m, and then be commanded and demanded 30Case 3:20-cv-00785-DPJ-FKB Document Filed 12/07/20 Page 31 of 42 lo no to the City of Jackson Impound Lot and act-as a night security guard because the City of Jackson cannot of lick the wisdom (o hite a security guard company which upon information und belief halt’ the cost of paying armed policeman, not to mention that the police departinent is short stalled ax it is(Plaiaulls have already described as well a shown images of this lot), from 6:00p.m. until sometimes 5:00a.m., and these Plaintifis ate still expected to be back us detectives without any overtime pay at 8:00 a.m, following being shot at by thieves. snukes in Unattended grass cutting maintenance: ao restroom tacilities(espectelly for females), no opportunity to leave and break for relic! of their mind or even check on their Lamtilies care, as Well as no lighting, and being-only pvo anned policemen for the ertire 40) plus acre lot of impounded ears in the dark, Please sce exhibit T, 64, The negligence and reckless behavior of these Defendants is shown even in the simplest of a request by Plaintiffs, that is a replacement of their BODY ARMOUR POLICY/ BULLET PROOF VEST, Hach Plaintiff avers that until just recently the City of Jackson and its Police Department has violated their awa Policy segarding Body Arinout Exhibit U is the City of Jacksoa Policy and Procedure for Body Ammoitt/Bullet Proof Vest, General Order No, 400-2, In fact, PliaiatiNs avers that Defendant Chiel James Davis has been so negligent and reckless with each of these PlaintiNls life, until the Gioneeal Order NB, 400-2, exbibit U/, has NOT ever been adopted by Chiei"Iames Davis therefore the Order as written was established in 2004, by the then Chief of Police Robert Moore, Furthermore, Plaintiffs make ihis reeord that Mayor Chwoeke Antor Lumumba aCase 3:20-cv-00785-DPJ-FKB Document Filed 12/07/20 Page 32 of 42 and Chief James Davis have been so reckless and negligent with all oF these Plaintiffs lives that the Mayor never insisted Uut Chief James Davis adopt the General Orders of the previous Chief of Police and Chief James Davis in bis own leadership way, never adoptad the some Which upon information and Belief, not only protects the City but themscives from actionsias found here, So in short, on The Lord God almighty knows if cithier of these Defendants understand the tinpdrtarice oftheir policy and procedures as well as ensuring thai ihe same are up to-date, However, each Plaintiff as found here, ksiew and begged this adm istration for up to date body armour/bullet proof vest especially in the cyes of such high homicide and talks of defunding the police, Plaintifis contend, anything otherwise is simply suicide to each officer; at least that is what Plaintiffs in this case avers 10, Furthermore, as a result of these Defendants negligence and reckless behavior, each Plaintiff’ has suffered severe imental stress for not having a NON-EXPIRED BULLET PROOF VEST FOR OVER AT LEAST [5] YEARS. ( After careful review of the \watranty on said vest, they expire it five years of wearing). 6S. |t follows thai, these Defendants knew or should have known that the bullet proof’ vest as provided {0 euch Plaintiff has an expiration date of around [5] years, As such, Plaintifts were going on active shosting calls and worst, looking for murder suspects without being properly protected, and the Mayer, Cheowke Antar Lumumba had the audacily to hold a meeting with the Plaintiffs and other officers and ask why is the morale so Jow in the Jackson Police Department, Plaintiil through their constitutional right of 32Case 3:20-cv-00785-DPJ-FKB Document1 Filed 12/07/20 Page 33 of A2 this lawsuit fling. responds by asking, “is he'serious.” Plaintiff contend that they are bout human und with the revent out breuks of violence in protesting, each ofthese Plaintif desires to-go home to their families breathing. Instead, each of these Plaintifly are going homie breathing but have (o look inte the eyes of those fiimily members and just pray to God they are not the next police officer shot and killed in the line of duty when such recklessness and negligence by these Defendants is 30 robust. Plaintifs contend that such negligence and recklessness could have been prevented by # chief of police und his steff being changed to ane that remembers what is was like to be on the streets of the Clay of Jackson, or better yet to a chief irom another state whom has seen in that state whar could happen whea those whom wear the badge is nol properly protected, Plaintills ventend. that even at the last meting-atlended by some Plaintiffs, upon information and belief some member of the City of lackson’s Clty Counsel decided to bravely state that they have “no confidence.” in the current police chief James Davis and his staff, but there again, the mayor, Cheowke Amar Lumumba, supports this chief in his endeavors, at least that is what he is found stating in a news conference regarding the Jackson Zou this summer, 66. Negligent hiring and supervising by these Defendants is even found fn the “Cease Fire Unit,” of the City of Jacksou Police Department. This unit hus/had 121 detectives for the entire urban of Jackson, and both are Plaintiffs in this lawsuit, Upon information-and belief this uuit is belleved to be responsible for ANY gun that is logged into evidenced of u crime, is tuken ty the stute crime lab for bullistle testing and other. 33Case 3:20-cv-00785-DPJ-FK8 Document1 Filed 12/07/20 Page-34 of 42 The issue is that one of these Plaintifis was tasked with the responsibility to transport there gins of which he has cempluined about, sine’ suid gui possessors could be anxious Wo retrieve those guns during transport and as such Defendants are putting the life of this Pininiiif at severe danger. 67. Moreover, Plaintills as well as others have mentioned to these Defendants that they are concemed that the “CHAIN OF CUSTODY,” with these puns as evidence could be compromised, causing theirinvestigation to be nullity, 68, Negligent hiring and supervising Chicf James Davis and his deputy chiefs is also found in the fact that the cease fire only [2| detectives for over at least [3] years have had lw use thelr personal cell phones to cummunicate the City of Jackson Police Department detective work, These ovo Plaintifls have complained for years thet they were not conilbttable aiving their personal cell phones of which JPD did not pay then for the cast of thelr personal céll phones, Even more concerning is the tact that citizens of the City of Jackson, whom has had to speak to these Plaintifis(detective whom was foreed to use their personal cell phones) regardiny their cise of fircarms(guns), did nor give the City oF Jhickson permission t allow the detectives to deal with their cases through the detectives personal cell phone, Upan information and beliel the City of Jackson could haye spent a sninimum of no greater than a lew dollars to get vell phones for this cease fire unit. And actually the City af Jackson, aller receiving @ letter of intent to sue in this case, did just that and provided the [2] detevtives.vith City uwned cell phones, Please see exhibit V. coCase 3:20-cv-00785-DPJ-FKB Document1 Filed 12/07/20 Page 35 of 42 Assuch, the negligence in hiring and supervising the Chief of police, James Davis, was reckless and extremely negligent, 69. Furthermore, to supporl Palntitts claims of negligence by these Defendants Plaintilts offer exhibit W, the organizational chart ofthe City of Juckson Polies Department. 70. Last, Plaintiffs contend thal these Defendants: are even negligent and severely reckless with even civilian employees with the City of Jackson Police during Specifically, the crime analy’is unit, which is the crime stats data, coding reporis and morewhich is crucial to an effective police department, However, Plaintiff Vanessa Johnson have complained io the City ef Jackson Police Department that they to are under staff and cannot effetive cnd accurately do the work of the crimes as purported in their duties without proper stalling, The City of Jackson, instead of biting persons to ALIA its obligation to the public for accurate information, they tured around and refused 1 give these PlainliNS the proper stall’ und compensation of overtime So that they ean eflectively perform their duties; 7A, Plaintiffs contend that the Mayor of the City of Jackson in the month of Noveniber. 2020 himself might have vielated the y of Jackson Policy whereby the olliciul signing ‘0 run for mayor for the City of Jackson is in January, 2021, but he is already: aetively’ campaigning before officially noticing as required whieh Plaintiff contend that found in the City of Juckson employee handbook numbers 3.1.4.5, and 3.1.5.2, that might he violating the City of Jackson Policies und procedures, Please see exhibit S. 35Case 3;20-cv-00785-DPL-FKB Document1 Filed 12/07/20 Page 36 of 42 72, Moreover, exhibit S, is 2 document from Defendant Derie Hearns concerning overtime punching in and out, but where Defendant Devic Heavns specifically states that the overtime of the mayors bodygusrds and staff is not applleable as is the other police officers and civilians, However, paragraph 3.5, 3.5.1, and 3.5.3 are the of Jnckson policy and procedure relating to NEPOTISM and whereby the mayor Cheowke Antar Lumumba is found (o be in direct violation of the same. CAUSE OF ACTION COUNT ONE; Violation of All Claims asserted by all Plaintiffs to this complaint Plaintifis repeats and realleges all paragraph and herein found in this complaint. Plaintiff's st, Sth and [4th U.S. Ci tutional Amendments Rights, Title 42 of the United States Code, Section 1983 42 U.S.C. Section 1983, Title VII of the Civil Rights Act of 1964, Sex discrimination, cuce discrimination, sexist discriminntion (gay rights), and SEATE CLAIMS OF; mental anguish, body injuries, Fraud, Breach of fiduciary duties to employees, misrepresentation, misuse of legal proceedings, joint tortfeasors, sirlet liability, negligent hiriig, negligent retention, negligent suporvising, intentional infliction of emotional distress, negligent infliction of emotional distress, brach of contract, individuully and conspiracy of misuppropriation of City’s finds that were earmarked to each Plaintiff and others, misuse of'state funds that belong to Plaintiffs, Intimidation, bullying, and siriet lisbility tor endangerment of each oflicer lives by not having cnough oflicers on duty at any tinie endungering each Plaintiff's life by not giving 36Case 9:20-cv-00785-DPJ-FKB Document Filed 12/07/20 Page 37 of 42 them a dated bullet proof vest (Defendants have just recently this year provided bullet proul'vest for gach PlaintilY, hut for yesirs PlaintiiT's vest were expired exposing them to immisent harm-and severe mental distress), Plaintifls contend that the avtions a7 all Defendants were negligent, reckless, willful and showed a reckless disregard for each Plainti{Y"s safety, life, income, livelihood, mental health, and rights as plead above. COUNT TWO; ALL CLAIMS LISTED IN THE ABOVE COUNT ONE. AND STATE CLAIMS (9) Plaintitts repeat and re-allege all previous paragraphs, as if set forth fully herein, and in the complaint, All Defendants are in violation of Plointifis STATE CLAIMS OF; mental anguish, body injuries, Fraud, Breuch of fiduciary duties to employees, misrepresentation, misuse ol” legal proceedings, joint tortiensors, sirlet liability, negligent hiring, negligent retention, negligent supervising, intentional infliction of emotional distress. negligent infliction of emotional distress, brach of contract, individually and conspiracy of misappropriation of” funds that were carmarked te each Plaintiff and others, misuse of state funds that betong to Pinintiffs, Intimidation, bullying, and sttiet lability for endangerment of each ollicer lives by not having enough officers on duly at any time endangering each Plaintii¥’s life by not giving them a dated bullet proof vest (Defendants have just recently this year provided bullet proat vest for edich Plaintiff; but for years Plaintifs vest were expired exposing them o imminent harm and severe mental distress). a7Case 3:20-cv-00785-DPJ-FKB Document1 Filed 12/07/20 Page 38 of 42 Plaintiffs contend (hat tie actions of al] Defendants were negligent, reckless, willful and showed a reckless disregard for euch Plaintiff's sulety, life, income, livelihood, mental health, and rights.as plead above. COUNT THREE: INTENTIONAL INELICTION OF EMOTIONAL DISTRESS, Plaintills repeat and re-allege all paragraphs as if set forth fully herein and in the complaint, Pkainiifl’s Ist, Sth and |4th U.S. Constitutional Amendments Rights, Title 42 of the United States Cade, Section 1983 42 U.S.C, Section 1983, Vitle VII of the Civil Rights Act of 1964, Sex dise mination, race discrimination, sexist discrimination (gay rights), and STATE CLAIMS OF: mental anguish, body injuries, Fraud, Breach of fiduciary dutics (0 employees, misrepreseniution, misuse of legal proceedings, joint torifeasers, strict liability, negligent hiring, negligent retention, negligent supervising, intentional infliction of emotional distress, negligent infligtion of emotional distress, brach: of contract, individually and conspiracy of misappropriation of City's funds thar were garmarked to each Plaintlif and others, misuse of state finds that belong to Plaintifls. Intimidation, bullying, and sixi liability Yor endangerment «teach oflicer lives by nut having enough officers on duly it any time endangering each Plaintif’s lifé by riot giving thent a dated bullet proof vest (Defendants have just eéeently this year provided bullet 38Case3!20-cv-00785-DPJ-FKB Document1 Filed 12/07/20 Page 39 of 42 proof vest for euch Plaintiff, but Jor years Pluintiti’s vest were expired exposing them to inimiinent harm und severe mental distress), Plaintifls contend that the actions ef all Defendants were negligent, reckless, willful and shoved a reckless disregard fer cach Plaintiff safety, life, ineome, livelihood, mental health, and rights as plead above, The uctions of all Defendants through their next pérson[s| of authority were negligent and showed # reckless disregard forall Plaintifls safety, life, income, livelihood, mental health, and riehts-as plead above. DAMAGES 34, The actions of Defendants were reckless and negligent, wanton, negligent per se, showed # reckless disregard for each Plaintiff's safety, Life, income, livelihood, mental health, and rights as plead above ay claimed in the above paragraphs, 55, Furthermore, the actions of’ Defendant, Mayor Cheowke Antar Lumumba and Chicf James Davis individually ‘and in his professional capacity were @ fatifleation of negligence, negligen! per se, reckless, nd caused each Plaintiff severe infliction of emotional distress as Well mental anguish, body pains, painand suffering, shock, freight, embarrassment, humiliation, feur of receiving reprimands or termination and loss of corned income. Additfonally, the actions of the remaiting Defendants individually and in their respective professional capacity has caused each Pinintifi’ severe infliction of emotional distress-as well mental anguish, body pains, pain aid suffering, shock, freight,Case 3:20-cv-00785-DPJ-FKB Document 1 Filed 12/07/20 Page 40 of 42 embarrassment, humiliation, fear of receiving reprimands or termination and loss of etrmed income. 56, As 4 consequence of the foregoing misconduct of all Defendants, Plaintiffs sustained puin and suflering, physical injury, excessive mental distress, depression, insomnia, shock, Hight, embarassment, loss on eamed income, loss of peaceable life without sullering, humiliation, embnrassment, countless monies to pay for help for every day. g.and every claiin as stated in the above paragraphs 67, Asa consequence oF the foregoing misconduct of these Defendants, cach Plaintil’ has. beet damaged in an amount of the limits ofthis Court's jurisdiction. RELIEF 38. WHEREFORE, each Plaintiff respectfully pray for the following relief: 1. Enter a Consent Decree relief declaring that the Mayor of the City ol’ Jackson must hot act asa certified or sworn police officer in making promises to the Jackson Police Department individually or-as a unit, 2. Enter a Consent Decree that cach and every Police Chief ofthe City of Jackson must adopted or-ervate the General Orders that the same is causing each and every police officerto abide by, And that the City of Jackson Police Chief must abide by the sane policy and procedures as the General Orders are stated, 3, Entera Consent Deeree that Chief James Davis MUST not use his religions belief on the police officers asa way'to get lel the public know that he teuwhes bible and that 40Case 3:20-cv-00785-DPJ-FKB Document Filed 12/07/20 Page 41 of 42 the officers should do the same in order to stop the high increase of hamicides i the City of Jackson, 4. Enter-an Order ending the Defendants’ from bullying, intimidating, and retaliating ugainst Plaintitty just heenuse of their authority over Pleintifls, 3. Award each Plaintiff with Compensatory damages, consequential damages, attorney fees, cont of litigation, cast of experts, economic damages, medical payments, loss of income, actual damages, diseretionary damages, excess damages, double damages, expectation damages, foreacenble damages, future damages, any damuyes that are-t0 be determined hy a jury, against all Defendants; 6. Award all Plaintiffs with Punitive damages against all Defendants, . Such injunctive relief as the Court deems necessary and. proper against ull Defendants; 8. Any other relief to Which the Plaintiffs as an entire group oF individually may be entitled but not listed above, RESPECTFULLY SUBMITTED this the 7th day of DECEMBER, 2020 ts) Abby Robinson wsy, MSB(105157) ABBY ROBINSON & ASSOCIATES LAW FIRM PLLC. 227 E, Pearl Street Jacksou, Mississippi 39201 Ph, 601-321.0343 Fax, 601-487-6326 Email; grobinsontawfirm@vahou,con Secondary; abby@askabbylaw.ore 4Case 3:20-cv-00785-DPI-FKS Document1 Filed 12/07/20 Page 42 of 42 I the undersigned do declare that | have filed the loregaing document with the Clerk of the Court ef whioin shall serve an electroni¢ copy of the same filing with each party ta this matter, ‘Submitted December 7.2020 Qe= a is! Abby Rob . MSB(0s187) = — ARBY ROBINSON & ASSOCIATES LAW FIRM PLLC 227, Peutl Street Jackson, Mississippi 39201 Ph, 601-321-9343 Fux, 601-487-6326 Email: arobinsumlawefiny@ yahoo.com Secondary; abby @askabbylawors