DOCUMENT 2

ELECTRONICALLY FILED
6/14/2023 4:40 PM
38-CV-2023-900242.00
CIRCUIT COURT OF
HOUSTON COUNTY, ALABAMA
CARLA H. WOODALL, CLERK
IN THE CIRCUIT COURT OF HOUSTON COUNTY, ALABAMA

LARRY PATRICK, )
)
Plaintiff, )
)
)
Vs. )
)
THE CITY OF DOTHAN, ALABAMA; )
STEPHANIE WINGFIELD; ROY KITTS; )
ALLISON HALL and FICTIOUS PARTIES )
1 - 3. Being those Persons, firms or entities who )
were responsible for and/or tasked with the )
duty to properly fill out and verify paperwork )
submitted to agencies for the funding program, )
which proximately caused or contributed to the )
Plaintiff’s damages and all other damages )
complained of herein whose true names are )
unknown to the Plaintiff but will be added by )
amendment when correctly ascertained. )

COMPLAINT

COMES NOW the Plaintiff, LARRY PATRICK, in the above styled caused, and brings

this action against the Defendants, THE CITY OF DOTHAN, ALABAMA, STEPHANIE

WINGFIELD, in her official capacity as a City of Dothan, Alabama, employee with the

Department of Leisure Services, and in her personal capacity as a City of Dothan, Alabama,

employee with the Department of Leisure Services; ROY KITTS, in his official capacity as

Assistant Director of Programming for The City of Dothan, Alabama Department of Leisure

Services, and in his personal capacity as Assistant Director of Programming for The City of

Dothan, Alabama Department of Leisure Services; ALLISON HALL, in her official capacity as

Director of The City of Dothan, Alabama Department of Leisure Services, and in her personal

capacity as Director of The City of Dothan, Alabama Department of Leisure Services; and

FICTITIOUS parties numbered 1 through 3, and alleges as follows:

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PARTIES

1. Plaintiff, LARRY PATRICK, is an adult resident of Houston County, Alabama.

2. Defendant, THE CITY OF DOTHAN, ALABAMA, is a municipality located in Houston

County, Alabama.

3. Defendant, STEPHANIE WINGFIELD, is an adult individual resident of Houston County,

Alabama.

4. Defendant, ROY KITTS, is an adult individual resident of Houston County, Alabama.

5. Defendant, ALLISON HALL, is an adult individual resident of Houston County, Alabama.

6. Fictitious Defendant No. 1, The person or entity who was responsible for the verification

of proper signatures in the feeding program paperwork operated by the City of Dothan, Alabama;

Fictitious Defendant No. 2, that or entity who or which was responsible for correctly preparing the

paperwork affiliated with the City of Dothan’s feeding program; Fictitious Defendant No. 3, that

person or entity who or which is successor in interest to any of the named and/or fictitious parties

hereinabove described.

FACTS

7. The Plaintiff hereby incorporates the foregoing material paragraphs as though fully set out

herein.

8. Larry Patrick was an employee of The City of Dothan, Alabama, for more than thirty-four

(34) years.

9. Mr. Patrick worked in the Department of Leisure Services. During his career with Leisure

Services, the City of Dothan elected to participate in a Federal program that provided lunches to

children during the summer.

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10. Larry Patrick was the Coordinator for the feeding program. One of his duties as the

Coordinator was to verify and provide accurate information in the various forms and paperwork

which were submitted by The City of Dothan to a state agency for reimbursement of costs for each

meal.

11. Furthermore, Larry Patrick was required to sign his name to said paperwork as part of the

verification process.

12. After an exemplary career, Larry Patrick retired from The City of Dothan in December of

2103.

13. On or about August 29, 2022, Larry Patrick learned that his name and signature had

continued to be used by The City of Dothan on paperwork submitted to the food program since his

retirement in December of 2013.

14. The continued unauthorized use of Larry Patrick’s name and signature was done without

Larry Patrick’s knowledge or consent.

COUNT I
NEGLIGENCE/WANTONNESS

15. The Plaintiff hereby incorporates the foregoing material paragraphs as though fully set out

herein.

16. The actions described above and the injuries suffered by the Plaintiff were the proximate

result of the Defendants’, both named and/or fictitious, negligence and/or wantonness in that the

Defendants had a duty to properly prepare, maintain and verify the food program paperwork

submitted by The City of Dothan to state agencies for reimbursement of meal costs. Defendants

further had a duty to discover and/or correct the food program paperwork prior to it being

submitted to the state agencies.

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17. The Defendants, both named and/or fictitious, breached said duty in that they failed to

adequately and reasonably prepare and/or insure that the food program was accurately prepared

and accurately verified by the Defendants before it was submitted to the proper state agencies for

reimbursement.

18. The Defendants, both named and/or fictitious, knew or should have known that Larry

Patrick retired from The City of Dothan Department of Leisure Services in December of 2013.

However, the Defendants continued to submit food program paperwork with Plaintiff’s

verification signature on said paperwork for more than eight (8) years after Plaintiff’s retirement.

19. As a direct and proximate result of Defendants’ said negligence and/or wantonness, the

Plaintiff suffered the following injuries and damages:

a. Plaintiff was caused to suffer mental anguish and emotional distress and will suffer same

in the future;

b. Plaintiff was caused to suffer damage to his good name, character and reputation in the

community;

c. Plaintiff was caused to suffer loss of capacity for the enjoyment of life and will suffer same

in the future;

WHEREFORE, PREMISES CONSIDERED, Plaintiff hereby demands judgment against

the Defendants, both named and/or fictitious, for compensatory and punitive damages in an amount

to be determined by the trier of fact, plus interest from the date of judgment and costs of this

litigation.

COUNT TWO
FORGERY

20. The Plaintiff hereby incorporates the foregoing material paragraphs as though fully set out

herein.
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21. The Defendants, both named and/or fictitious, intentionally and falsely used Plaintiff’s

name and signature on food program paperwork documents submitted to state agencies for

reimbursement of food costs.

22. The Defendants, both named and/or fictitious, intentionally used Plaintiff’s name and

signature without Plaintiff’s knowledge or permission for more than eight (8) years after Plaintiff’s

retirement from The City of Dothan, Alabama.

WHEREFORE, PREMISES CONSIDERED, Plaintiff hereby demands judgment against

the Defendants, both named and/or fictitious, for compensatory and punitive damages in an amount

to be determined by the trier of fact, plus interest from the date of judgment and costs of this

litigation.

COUNT THREE
NEGLIGENT HIRING, TRAINING AND SUPERVISION

23. The Plaintiff hereby incorporates the foregoing material paragraphs as though fully set out

herein.

24. The Defendants, both named and/or fictitious, had a duty to hire, train and supervise the

employees of The City of Dothan Department of Leisure Services.

25. The Defendants, both named and/or fictitious, breached that duty by failing to train and

supervise Stephanie Wingfield regarding the performance of her job duties with regard to the

preparation and verification of the City’s food program paperwork.

26. The Defendants, both named and/or fictitious, knew or should have known that Plaintiff’s

name continued to be used on said paperwork for more than eight (8) years after his retirement

from The City of Dothan, Alabama.

27. As a proximate result of the Defendants’ negligent hiring, training and supervision of

Stephanie Wingfield, Plaintiff suffered the following damages:

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a. Plaintiff was caused to suffer mental anguish and emotional distress and will suffer same

in the future;

b. Plaintiff was caused to suffer damage to his good name, character and reputation in the

community;

c. Plaintiff was caused to suffer loss of capacity for the enjoyment of life and will suffer same

in the future;

WHEREFORE, PREMISES CONSIDERED, Plaintiff hereby demands judgment against

the Defendants, both named and/or fictitious, for compensatory and punitive damages in an amount

to be determined by the trier of fact, plus interest from the date of judgment and costs of this

litigation.

COUNT FOUR
CIVIL CONSPIRACY

28. The Plaintiff hereby incorporates the foregoing material paragraphs as though fully set out

herein.

29. The Defendants, both named and/or fictitious, had an agreement with each other to

intentionally and falsely use Plaintiff’s name and signature without Plaintiff’s knowledge or

consent.

30. Defendants continuously used Plaintiff’s name on food program paperwork used for

reimbursement of food costs for more than eight (8) years after Plaintiff retired from The City of

Dothan, Alabama.

31. As a proximate result of the Defendants’ civil conspiracy, Plaintiff suffered the following

damages:

a. Plaintiff was caused to suffer mental anguish and emotional distress and will suffer same

in the future;
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b. Plaintiff was caused to suffer damage to his good name, character and reputation in the

community;

c. Plaintiff was caused to suffer loss of capacity for the enjoyment of life and will suffer same

in the future;

WHEREFORE, PREMISES CONSIDERED, Plaintiff hereby demands judgment against

the Defendants, both named and/or fictitious, for compensatory and punitive damages in an amount

to be determined by the trier of fact, plus interest from the date of judgment and costs of this

litigation.

Dated this the 14th day of June, 2023.

William C. Maddox
William C. Maddox (MAD021)
Law Offices of William C. Maddox, P.C.
200 Grove Park Lane
Suite 670
Dothan, Alabama 36305
334-678-8100 telephone
334-793-5144 facsimile
chrismaddoxlaw@gmail.com

JURY DEMAND

Plaintiff hereby demands a trial by struck jury of all issues and demands in this cause.

William C. Maddox
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PLEASE SERVE DEFENDANTS AT:

The City of Dothan

126 North Saint Andrews Street
Dothan, Alabama 36303

Stephanie Wingfield
3301 Redmond Road
Dothan, Alabama 36303

Roy Kitts
852 Broad Street
Newville, Alabama 36353

Allison Hall
126 North Saint Andrews Street
Dothan, Alabama 36303