Case 4:24-cv-00023-BSM Document 1 Filed 01/09/24 Page 1 of 16

FILED
U.S. DISTRICT COURT
IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT ARKANSAS

EASTERN DISTRICT OF ARKANSAS JAN O9 2024

CENTRAL DIVISION
TAMMY H. DOWNS, CLERK
BRYAN ALDRIDGE, By: ___:-:::~5~~DiK
EPCLERK

Plaintiff,

V. Case No.: 4: 24-cv-2J-BSM

PULASKI COUNTY, ARKANSAS, ***JURY TRIAL DEMANDED

a Body Corporate and Politic,
RONALD LEE ROUTH,
in his individual capacity, and
RODNEY SHEPHERD,
• d to o·1stnc
Th •1s case ass1gne Miller
• t J udge _ __
in his individual capacity,
and to Magistrate Judge_K_e_ar_n_e_y_ _ _ __
Defendants

COMPLAINT

NOW COMES Plaintiff, BRYAN ALDRIDGE, by and through his attorneys, LAUX LAW

GROUP, and for his cause of action against Defendants, PULASKI COUNTY, ARKANSAS, a

Body Corporate and Politic, RONALD LEE ROUTH, in his individual capacity and RODNEY

SHEPHERD, in his individual capacity, states as follows:

Introduction

This is a civil rights action brought pursuant to 42 U.S.C. § 2000e, et seq. (Title VII of the

Civil Rights Act of 1964 as amended) in order to recover damages against Defendant, PULASKI

COUNTY, ARKANSAS (hereafter "PULASKI CO."), RONALD LEE ROUTH (hereafter

"ROUTH") and RODNEY SHEPHERD (hereafter "SHEPHERD") for the unlawful and

conspiratorial discriminatory employment practices to which Plaintiff, BRYAN ALDRIDGE

(hereafter "PLAINTIFF") has been subjected, said practices resulting in his unwarranted

termination. PLAINTIFF has suffered various types of damages on account of the conduct herein

alleged.
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JURISDICTION

1. Jurisdiction and venue of this Court are invoked pursuant to 42 U.S.C. § 2000e-5

and 28 U.S.C. §§ 1331 and 1391. The unlawful employment practices and misconduct alleged to

have been committed against PLAINTIFF was committed in the State of Arkansas, and in Pulaski

County, Arkansas.

PARTIES

2. At all relevant times, PLAINTIFF was and is a citizen of the United States of

America, and he is, therefore, entitled to all legal and constitutional rights afforded citizens of the

United States of America. As a person of African American heritage, PLAINTIFF is a member of

a class protected by Title VII. At all relevant times, PLAINTIFF was an employee of Pulaski

County Juvenile Detention Center (hereafter "PCIDC" or "the facility").

3. On June 20, 2023, PLAINTIFF filed charges ofracial discrimination and retaliation

against PULASKI CO. with the Equal Employment Opportunity Commission (EEOC) stemming

from his unlawful February 9, 2023 termination from PCIDC, where he had worked since June

2004 without issue. On October 11, 2023, the EEOC issued him a Dismissal and Notice of Rights

("Right to Sue Letter"). See Exhibit A.

4. PLAINTIFF filed the instant lawsuit within the requisite ninety (90) days of

PLAINTIFF's receipt of his October 11, 2023 EEOC Right to Sue Letter.

5. At all relevant times, including February 9, 2023, PULASKI CO. was and is a

public body corporate created by the General Assembly for the State of Arkansas pursuant to Ark.

Code Ann.§ 14-14-501. PULASKI CO. owns and operates PCDJC, a 48-bedjuvenile detention

facility located at 3001 W. Roosevelt Rd., Little Rock, Arkansas, and serving the most populous

county in Arkansas.

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6. Title VII defines an employer as "a person engaged in an industry affecting

commerce who has fifteen or more employees ... and any agent of such person ... " 42 U.S.C. §

2000e(b). An individual qualifies as an "employer" under Title VII if he or she serves in a

supervisory position and exercises significant control over the plaintiffs hiring, firing or

conditions of employment. See, e.g., Garcia v. ElfAtochem North America, 28 F.3d 446 (5 th Cir.

1994); Paronline v. Unisys Corp., 879 F.2d 100 (4th Cir. 1989).

7. PULASKI CO. is an employer with more than fifteen (15) employees and, at all

relevant times, PULASKI CO. was PLAINTIFF's employer.

8. At all relevant times, ROUTH was the director of PCJDC and an employee of

PULASKI CO. At all relevant times, SHEPHERD was the assistant director of PCJDC and an

employee of PULASKI CO.

PERTINENT FACTS

9. On June 28, 2004, PLAINTIFF was hired as a detention officer at PDJDC where

he oversaw juveniles sent to the facility and generally helped maintain order within the facility. In

2010, PLAINTIFF was promoted to the supervisory position of Juvenile Detention Shift

Supervisor where he was responsible for providing efficient management, supervision and control

of PCJDC shift operations.

10. In April 2020, ROUTH was named interim director of PCJDC. Soon thereafter,

ROUTH was appointed director of the facility, a position he occupied at all relevant times,

including June 2022. As PCJDC director, ROUTH was responsible for the overall functioning of

the facility.

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11. In June 2022, SHEPHERD, assistant director of PDJDC, was ROUTH's direct

subordinate. In June 2022, PLAINTIFF's chain of command in descending order was ROUTH,

SHEPHERD and then PLAINTIFF, who supervised multiple detention officers.

PLAINTIFF OBSERVES EVIDENCE OF SEXUAL ASSAULT AGAINST A JUVENILE

COMMITTED BY ROUTH. AND PLAINTIFF REPORTS ROUTH TO PULASKI CO.

12. In May 2022, PLAINTIFF attended an informal meeting in ROUTH's office, along

with Stacey Smith, ROUTH's assistant, SHEPHERD and ROUTH. During this meeting,

PLAINTIFF, Ms. Smith and SHEPHERD saw a video on ROUTH's computer which depicted

ROUTH approaching a juvenile at the facility and touching him between the legs, which

constitutes the sexual assault of a juvenile.

13. When asked by PLAINTIFF why he touched the juvenile between his legs, ROUTH

responded that he did it "to see if [the juvenile] was still hard."

14. Within a day or two of seeing the video in ROUTH's office, PLAINTIFF, still

shaken by what he saw, reported ROUTH's misconduct to PCJDC supervisory staff.

15. Prior to June 1, 2022, PULASKI CO., through PCJDC, was aware of allegations of

sexual misconduct committed by ROUTH against juveniles within the facility.

16. The facility did not initiate an internal investigation of the allegations against

ROUTH in response to PLAINTIFF's reporting. Despite the serious conduct of which ROUTH

was accused-conduct PLAINTIFF told PULASKI CO. was depicted in facility video recording-

ROUTH remained in place as the director of the facility for the remainder of May 2002, through

all of June 2022 and well into July 2022.

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AFTER PLAINTIFF REPORTED ROUTH TO PULASKI CO. FOR SEXUAL ABUSE OF A

JUVENILE, ROUTH CONTINUED TO COMMIT ACTS OF SEXUAL MISCONDUCT ON
JUVENILES

17. Between June 18 and 19, 2022, ROUTH committed acts of sexual abuse on a

juvenile(s) within the facility. Upon information and belief, this juvenile victim(s) reported

ROUTH's criminal conduct to the Arkansas State Police (ASP).

18. On or about June 23, 2022, the ASP Crimes Against Children Division (CACD),

began an investigation stemming from the complaint(s) of the juvenile victim(s) that ROUTH

engaged in sexual misconduct at PCJDC the prior week.

19. On July 21, 2022, the allegations against ROUTH-which constitute criminal

charges of Second Degree Sexual Assault in violation of Ark. Code Ann. § 5-14-125(a)(4)(A)(i)

and Harassment against minors in violation of Ark. Code Ann. § 5-71-208(a)(5)-were referred

to the Pulaski County Sheriffs Office (PCSO) for criminal investigation. Sgt. Terrance Mems

was the assigned PCSO criminal investigator. In July 2022, ROUTH paid on administrative leave

and not terminated.

20. On or around July 23, 2022, as part of his PCSO criminal investigation of ROUTH,

Sgt. Mems interviewed current and former PCJDC employees who knew and worked with

ROUTH, and current and former juvenile detainees with whom ROUTH interacted.

21. The first juvenile questioned told Sgt. Mems that ROUTH took photographs of him,

including during a mandatory strip search. The first juvenile reported that ROUTH asked him

questions about his genitalia and the genitalia of other juveniles at the facility.

22. The second juvenile questioned described to Sgt. Mems the sexual assault incident

depicted on ROUTH's computer video which PLAINTIFF reported to PULASKI CO. back in May

2022.

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23. PLAINTIFF was questioned by Sgt. Mems and told him about the video he

observed on ROUTH's computer. PLAINTIFF told him that ROUTH admitted to purposefully

touching the juvenile's genitals.

24. Several other individuals interviewed by Sgt. Mems provided personal accounts of

witnessing ROUTH ask juveniles about the size of their genitals, witnessing him hug and kiss

juveniles and other inappropriate actions and comments.

25. On August 8, 2022, Sgt. Mems interviewed ROUTH who was accompanied by a

criminal defense lawyer. ROUTH acknowledged the video but claimed he did not touch the

juvenile's genitals. ROUTH added that the video would have been reviewed by several staff

members as a matter of course, intimating that everyone at the facility knew about what he did.

26. On or around January 26, 2023, following his investigation, Sgt. Mems concluded

that there was probable cause to arrest ROUTH for unlawful conduct occurring between May 16,

2022 and July 20, 2022.

27. In an affidavit dated January 26, 2023, Sgt. Mems described his investigation of

ROUTH. In his affidavit, Sgt. Mems identified PLAINTIFF as providing him with incriminating

statements about the video depicting ROUTH's sexual assault. Sgt. Mems mentioned in his

affidavit that others at the facility had viewed the video showing ROUTH's sexual assault but he

did not identify those staff members by name.

28. Sgt. Mems stated that several other PCJDC staff members viewed the video of

ROUTH sexually assaulting the juvenile but they were not identified by name in his affidavit.

29. Shortly after his statement to Sgt. Mems, ROUTH resigned from his position as

director of PCJDC.

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30. On January 30, 2023, ROUTH was arrested by PCSO, about eight (8) months after

PLAINTIFF came forward regarding the video of ROUTH's sexual assault and six (6) months

after the potential criminal case was referred to PCSO. Around that time, the media began

reporting on ROUTH's arrest, and Sgt. Mems' affidavit went public.

31. On February 1, 2023, ROUTH appeared in Pulaski County District Court and

pleaded innocent to one ( 1) felony count of second-degree sexual assault and three (2)

misdemeanor counts of harassment.

PULASKI CO. TERMINATES PLAINTIFF NINE (9) DAYS AFTER ROUTH'S ARREST ON
CHARGES OF SEXUAL ASSAULT OF JUVENILES AT THE FACILITY

32. On February 9, 2023, eight days after ROUTH's arrest on charges of sexual assault,

in a three sentence letter, SHEPHERD terminated PLAINTIFF after nearly twenty years on the

job. SHEPHERD's February 9, 2023 termination letter read:

At this time, it has been determined that you are no longer a go (sic)
fit for the Pulaski County Detention Facility. Therefor (sic) have
elected to cease your employment with the Pulaski County
Detention Center effective immediately. I wish you luck in all your
future endeavors.

33. On February 6, 2023, PLAINTIFF and two (2) detention officers had an interaction

with a violent juvenile the type of which was not uncommon for the facility. Because of the violent

nature of the juvenile's conduct, restraint and isolation was necessary, and this was a common

response to such conduct occurring at PCJDC historically. PLAINTIFF and the two officers all

engaged in the same conduct while interacting with the juvenile.

34. On February 7, 2023, PCJDC began an investigation of the allegations against

PLAINTIFF and the two officers. PLAINTIFF was terminated before the conclusion of the

investigation of the alleged conduct. The two officers were not terminated.

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35. Upon information and belief, the allegations against PLAINTIFF were not

sustained. Despite this exculpatory finding, PLAINTIFF remained terminated.

DISPARATE REASONS FOR PLAINTIFF'S FEBRUARY 2023 TERMINATION

36. According to an official PCJDC document dated March 2, 2023, the reason that

most closely describes the reason PLAINTIFF was terminated was "customer complaints."

According to this official document, the "final incident that caused the discharge" was that a

"compliant (sic) against [PLAINTIFF] was filed with the Arkansas State Police." According to

this official PCJDC document, "[t]here was a compliant (sic) filed with the Arkansas State Police

against [PLAINTIFF]. [PLAINTIFF] was placed on administrative leave pending the outcome of

the investigation. At the conclusion of the investigation, [PLAINTIFF] was discharged."

37. According to an official PCJDC document dated March 24, 2023, the reason that

most closely describes the reason PLAINTIFF was terminated was that he "failed to meet

employer standards." According to this official PCJDC document, the "final incident that caused

the discharge" was that PLAINTIFF, a PCJDC veteran of nearly 20 years, "was not a good fit for

Juvenile Detention."

38. According to both the March 2, 2023 official PCJDC document and the March 24,

2023 official PCJDC document, there were not any witnesses to the alleged February 7, 2023

incident which led to PLAINTIFF's termination.

39. According to both sets of official PDJDC documents PLAINTIFF's termination did

not involve the violations of any facility policies. According to both sets of official documents,

PLAINTIFF was terminated by his supervisor, SHEPHERD.

40. According to both sets of official PCJDC documents, PLAINTIFF performed his

job duties satisfactorily in the past. According to both sets of official documents, PLAINTIFF

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performed his job duties to the best of his ability. The information contained in both sets of official

documents was provided by the same individual, PULASKI CO. employee, Jamie Martin.

COUNTI
RACE DISCRIMINATION-RETALIATION
PULASKI CO.

41. Plaintiff hereby incorporates and re-alleges the above paragraphs as though fully

alleged in Count I.

42. Title VII of the Civil Rights Act of 1964 (as amended) is a federal law that prohibits

employers from discriminating against employees on the basis of race. A plaintiff may prove

intentional discrimination using either direct or circumstantial evidence. Evidence is "direct" if it

establishes a specific link between the alleged discriminatory animus and the challenged decision,

sufficient to support a finding by a reasonable fact finder that an illegitimate criterion actually

motivated the employer's decision.

43. The law prohibits punishing employees for asserting their rights to be free from

employment discrimination including retaliation. Asserting these rights is called "protected

activity." It is unlawful to retaliate against employees for participating in a complaint process.

44. Providing statements to law enforcement officers in the investigation of a felony is

protected from retaliation under all circumstances.

45. Reporting sexual misconduct in the workplace is a protected activity. It is unlawful

for an employer to retaliate against an employee for intervening to protect other persons from

sexual harassment and/or sexual assault.

46. PLAINTIFF engaged in protected activity when he complained to PULASKI CO.

in May 2022 about the sexual assault he observed ROUTH commit on the video recording.

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47. PLAINTIFF engaged protected activity in June 2022 when he reported ROUTH's

violations of law to Sgt. Mems during the CACD investigation.

48. Rather than commend PLAINTIFF for reporting ROUTH's criminal behavior,

PULASKI CO., through its employees, agents and/or servants, including SHEPHERD, instead

retaliated against him by fabricating a claim against him and terminating him. An employer may

not fire, demote, harass or otherwise retaliate against an individual opposing discrimination or

harassment.

49. These actions committed by PULASKI CO. constitute adverse employment

actions. PULASKI CO. terminated PLAINTIFF because he complained to PDJDC about

ROUTH's sexual misconduct and harassment.

50. The deprivation of PLAINTIFF's constitutional rights which was committed by

PULASKI CO. and its employees, agents and/or servants was unnecessary and unreasonable.

Therefore, PULASKI CO. is liable in damages to PLAINTIFF, including compensatory damages,

actual damages, punitive damages, costs and attorney's fees.

COUNT II
CIVIL CONSPIRACY

51. PLAINTIFF hereby incorporates and re-alleges the above paragraphs as though

fully alleged in Count II.

52. To prove a conspiracy claim, a plaintiff must show that a defendant conspired with

others to deprive him of a constitutional right, that at least one alleged co-conspirator committed

an overt act in furtherance of the conspiracy and that the act injured him.

53. PLAINTIFF alleges herein that ROUTH and SHEPHERD conspired to terminate

PLAINTIFF in retaliation for his reporting ROUTH's sexual misconduct to PCSO.

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54. The deprivation of PLAINTIFF's constitutional rights which was committed by

ROUTH and SHEPHERD was unnecessary, unreasonable and willfully malicious. Therefore,

ROUTH and SHEPHERD, and each of them, are liable in damages to PLAINTIFF, including

compensatory damages, actual damages, punitive damages, costs and attorney's fees.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff, BRYAN ALDRIDGE, by and through his attorneys, LAUX

LAW GROUP, seeks the following relief for the unlawful employment practices and

unconstitutional conduct described above:

1. That the Court declare PLAINTIFF has been subjected to

unlawful discriminatory practices, and that the Court issue a
declaratory judgment that the PULASKI CO. engages m
discriminatory employment practices and retaliation;

2. That the Court issue an injunction for the purpose of

prohibiting further acts of race discrimination in the future;

3. That the Court order the reinstatement of PLAINTIFF as First

Shift Supervisor at the facility;

4. That Defendants be required to pay PLAINTIFF's

compensatory damages, including lost wages, and emotional
damages;

5. That Defendants be required to pay punitive damages;

6. That PULASKI CO. be required to pay reasonable costs and

attorney fees; and

7. That PLAINTIFF receive any other equitable, legal and just

relief as this Honorable Court deems appropriate.

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Respectfully submitted,

Michael J. Laux
Michael J. Laux •
~
E. Dist. Arkansas Bar No. 6278834
One of the Attorneys for PLAINTIFF
400 W. Capitol Avenue, Suite 1700
Little Rock, AR 72201
Telephone: (501) 242-0750
Facsimile: (501) 372-3482
E-mail: mlaux@lauxlawgroup.com
mikelaux@icloud.com

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U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

Little Rock Area Office
820 Louisiana St, Suite 200
Little Rock, AR 72201
(501) 900-6130
Website: www.eeoc.gov

DETERMINATION AND NOTICE OF RIGHTS

(This Notice replaces EEOC FORMS 161, 161-A & 161-B)

Issued On: 10/11/2023

To: Mr, BRYAN ALDRI~GE
hos w. Mellwood Rd
LITTLE ROCK, AR 72204
Charge No: 493-2023-01146
EEOC Representative and email: JOHNNY GLOVER
Investigator
johnny.glover@eeoc.gov

DETERMINATION OF CHARGE

The EEOC issues the following determination: The EEOC will not proceed further with its
investigation and makes no determination about whether further investigation would establish
violations of the statute. This does not mean the claims have no merit. This determination does not
certify that the respondent is in compliance with the statutes. The EEOC makes no finding as to
the merits of any other issues that might be construed as having been raised by this charge.

NOTICE OF YOUR RIGHT TO SUE

This is official notice from the EEOC of the dismissal of your charge and of your right to sue. If
you choose to file a lawsuit against the respondent(s) on this charge under federal law in federal
or state court, your lawsuit must be filed WITHIN 90 DAYS of your receipt of this notice.
Receipt generally occurs on the date that you (or your representative) view this document. You
should keep a record of the date you received this notice. Your right to sue based on this charge
will be lost if you do not file a lawsuit in court within 90 days. (The time limit for filing a lawsuit
based on a claim under state law may be different.)
If you file a lawsuit based on this charge, please sign-in to the EEOC Public Portal and upload the
court complaint to charge 493-2023-01146.

On behalf of the Commission,

Digitally Signed By:Edmond Sims

10/11/2023
Edmond Sims
Acting District Director
 Case 4:24-cv-00023-BSM Document 1 Filed 01/09/24 Page 14 of 16

Cc:
Chastity Scifres
Pulaski County Administration
201 BROADWAY ST STE 100
Little Rock, AR 72201

Mallory Floyd
1415 W 3RD ST
Little Rock, AR 72201

Please retain this notice for your records.

 Case 4:24-cv-00023-BSM Document 1 Filed 01/09/24 Page 15 of 16
Enclosure with EEOC Notice of Closure and Rights (01/22)

INFORMATION RELATED TO FILING SUIT

UNDER THE LAWS ENFORCED BY THE EEOC
(This information relates to filing suit in Federal or State court under Federal law. Ifyou also
plan to sue claiming violations ofState law, please be aware that time limits may be shorter and
other provisions of State law may be different than those described below.)

IMPORTANT TIME LIMITS - 90 DAYS TO FILE A LAWSUIT

If you choose to file a lawsuit against the respondent( s) named in the charge of discrimination,
you must file a complaint in court within 90 days of the date you receive this Notice. Receipt
generally means the date when you (or your representative) opened this email or mail. You should
keep a record of the date you received this notice. Once this 90-day period has passed, your
right to sue based on the charge referred to in this Notice will be lost. If you intend to consult an
attorney, you should do so promptly. Give your attorney a copy of this Notice, and the record of
your receiving it (email or envelope).
If your lawsuit includes a claim under the Equal Pay Act (EPA), you must file your complaint in
court within 2 years (3 years for willful violations) of the date you did not receive equal pay. This
time limit for filing an EPA lawsuit is separate from the 90-day filing period under Title VII, the
ADA, GINA, the ADEA, or the PWFA referred to above. Therefore, if you also plan to sue under
Title VII, the ADA, GINA, the ADEA or the PWFA, in addition to suing on the EPA claim, your
lawsuit must be filed within 90 days of this Notice and within the 2- or 3-year EPA period.

Your lawsuit may be filed in U.S. District Court or a State court of competent jurisdiction.
Whether you file in Federal or State court is a matter for you to decide after talking to your
attorney. You must file a "complaint" that contains a short statement of the facts of your case
which shows that you are entitled to relief. Filing this Notice is not enough. For more information
about filing a lawsuit, go to https://www.eeoc.gov/employees/lawsuit.cfm.
ATTORNEY REPRESENTATION

For information about locating an attorney to represent you, go to:

https://www.eeoc.gov/employees/lawsuit.cfm.
In very limited circumstances, a U.S. District Court may appoint an attorney to represent individuals
who demonstrate that they are financially unable to afford an attorney.

How TO REQUEST YOUR CHARGE FILE AND 90-DAY TIME LIMIT FOR REQUESTS
There are two ways to request a charge file: 1) a Freedom of Information Act (FOIA) request or
2) a "Section 83" request. You may request your charge file under either or both procedures.
EEOC can generally respond to Section 83 requests more promptly than FOIA requests.
Since a lawsuit must be filed within 90 days of this notice, please submit your FOIA and/or
Section 83 request for the charge file promptly to allow sufficient time for EEOC to respond and
for your review.
To make a FOIA request for your charge file, submit your request online at
https://eeoc.arkcase.com/foia/portal/login (this is the preferred method). You may also submit a
FOIA request for your charge file by U.S. Mail by submitting a signed, written request
 Case 4:24-cv-00023-BSM Document 1 Filed 01/09/24 Page 16 of 16
Enclosure with EEOC Notice of Closure and Rights (01/22)

identifying your request as a "FOIA Request" for Charge Number 493-2023-01146 to the
District Director at Edmond Sims, 200 Jefferson Ave Suite 1400
Memphis, TN 38103.
To make a Section 83 request for your charge file, submit a signed written request stating it is
a "Section 83 Request" for Charge Number 493-2023-01146 to the District Director at Edmond
Sims, 200 Jefferson Ave Suite 1400
Memphis, TN 38103.
You may request the charge file up to 90 days after receiving this Notice of Right to Sue. After
the 90 days have passed, you may request the charge file only if you have filed a lawsuit in court
and provide a copy of the court complaint to EEOC.
For more information on submitting FOIA requests, go to
https://www.eeoc.gov/eeoc/foia/index.cfm.
For more information on submitted Section 83 requests, go to https://www.eeoc.gov/foia/section-
83-disclosure-information-charge-files.