HomeMy WebLinkAbout2016CV00966 - ARAUJO & GONZALES V. CITY OF FORT COLLINS, ET AL - 001a - COMPLAINT AND JURY TRIAL DEMANDIN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No:
KENNYBERG ARAUJO,
Plaintiffs,
v.
THE CITY OF FORT COLLINS, Colorado, a home rule municipality;
DONALD VAGGE, former Deputy Chief of Police, in his individual and official capacities; and
GARY SHAKLEE, Police Sergeant, in his individual and official capacities;
Defendants.
COMPLAINT AND JURY TRIAL DEMAND
COMES NOW, Plaintiff Kennyberg Araujo, through his attorney, Marc F. Colin, of the
law firm Bruno, Colin & Lowe, P.C., and hereby submits his Complaint and Jury Demand
against the above named defendants as follows:
I. NATURE OF THE ACTION
This is an action under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C §
2000e et seq. alleging discrimination and retaliation in violation of 42 U.S.C. § 1981, against
Defendants, to correct unlawful employment practices on the basis of race and in retaliation for
engaging in protected activities, and to provide appropriate relief to other Hispanic employees of
the defendant city who have been and continue to be adversely affected by such practices. The
Plaintiff, Kennyberg Araujo, alleges that Defendants discriminated against him when they
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targeted him for adverse employment actions because of his Hispanic appearance, accent and
Brazilian origin. Plaintiff further alleges that Defendants retaliated against him when he engaged
in protected activity including seeking accommodation and/or complaining about discrimination.
II. INTRODUCTION
1. This is a national origin (Brazilian) and race (Hispanic) discrimination and
retaliation case. Mr. Araujo was born and raised in Brazil and is of Brazilian descent. He
attended high school and college in Brazil and moved to be in the U.S. in 1991. He subsequently
obtained a Bachelor of Arts Degree in Psychology and Social Science from the University of
Wyoming in 2006.
2. Mr. Araujo was hired by the City of Fort Collins in January of 2007.
3. The City of Fort Collins is a Home Rule municipality and Defendant Vagge was a
final policy maker and Deputy Chief of Police for the Fort Collins Police Department.
Defendant Shaklee was and is employed as a Police Sergeant for the Fort Collins Police
Department. Defendant Shaklee was the former supervisor of Plaintiff herein. Defendants
Vagge and Shaklee are sued in both their official and individual capacities.
4. From January of 2007 until June of 2015, when he was forced to resign from his
employment as a Detective with the Fort Collins Police Department due to Defendants’
harassment and retaliation, Plaintiff Araujo was a consistently exemplary employee.
5. When Defendant Shaklee, who is Caucasian and American born, became Mr.
Araujo’s direct supervisor, Mr. Araujo’s treatment at the Fort Collins Police Department changed
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markedly. Despite his outperformance of similarly-situated American-born Caucasian
colleagues, Mr. Araujo’s performance was consistently criticized for false or otherwise
pretextual reasons by Sgt. Shaklee, while American-born Caucasian colleagues who engaged in
the same performance practices were not subject to criticism.
6. Sgt. Shaklee has a history of singling out employees of Hispanic origin for
criticism, unwarranted complaints and abusive treatment. Sgt. Shaklee’s discriminatory
practices were well known to Defendant Vagge, who, as the Deputy Chief of the Police
Department, actually conspired with Sgt. Shaklee in furtherance of his discriminatory practices,
to protect Sgt. Shaklee from the consequences of his discriminatory practices and/or to otherwise
assist Sgt. Shaklee in retaliating against subordinate employees who complained of such
unlawful discriminatory practices or who supported the complaints of Det. Araujo and other
Hispanic employees.
7. Soon after Mr. Araujo complained about discrimination, he was subjected to a
series of false Complaints made by Sgt. Shaklee or filed at Sgt. Shaklee’s direction.
8. In pursuing these false complaints against Det. Araujo, Sgt. Shaklee violated
multiple Fort Collins Police Department policies and procedures. Sgt. Shaklee also induced
others, including his wife, a Fort Collins Police Detective, to file false complaints against the
Plaintiff and then, in further violation of policy, investigated and sustained the false complaints
which he had initiated or caused to be initiated. Defendant Vagge was, upon information and
belief, not only aware that Sgt. Shaklee was engaging in this practice with regard to Plaintiff, but
was also aware that Sgt. Shaklee had a long standing pattern and practice of singling out, or
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otherwise targeting Hispanic employees for unwarranted adverse employment action and both
encouraged such actions and failed to act to stop them from reoccurring, culminating in
Plaintiff’s resignation from the Agency.
9. Sgt. Shaklee’s discriminatory and retaliatory practices had been the subject of
prior complaints by other Hispanic employees. The City of Fort Collins had knowledge of Sgt.
Shaklee’s discriminatory and retaliatory practices yet failed to take any action to address them.
Rather, Defendant Vagge engaged in a pattern of conduct designed to protect Defendant Shaklee
from the complaints of Hispanic and other employees and to allow Defendant Shaklee to
continue such practices of discrimination and retaliation.
10. As a result of being subjected to both discrimination and retaliation by Sgt.
Shaklee, Plaintiff Araujo initiated an internal Complaint against Defendant Shaklee. This
Complaint included claims that Sgt. Shaklee had singled Plaintiff out for false claims of poor
performance due to his race and national origin, that Defendant Shaklee had induced others to
make similarly false allegations against Plaintiff, and that Defendant Shaklee had violated policy
by investigating his own complaints and those which he caused to be initiated and then
recommending that such false complaints be sustained. Plaintiff Araujo further alleged that
through the above actions and in making false complaints, Sgt. Shaklee had departed from the
truth, an offense which, if sustained, would have mandated Sgt. Shaklee’s termination.
11. Defendants Fort Collins and Vagge, as a final policy maker for the Fort Collins
Police Department, sustained Plaintiff’s complaints against Sgt. Shaklee with the exception of
his allegations that Sgt. Shaklee had departed from the truth. The departing from the truth charge
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was not sustained despite the fact that in order for the other policy violations to have been
sustained, Sgt. Shaklee must have repeatedly departed from the truth. Rather, Defendants Vagge
and Fort Collins attributed Defendant Shaklee’s multiple false statements to inadvertent
mistakes. As a result, no significant action was taken by Defendants Vagge and Fort Collins
against Sgt. Shaklee for his discriminatory practices or for the sustained policy violations arising
therefrom. Defendants Fort Collins and Vagge thereby encouraged Sgt. Shaklee to continue his
discriminatory and retaliatory practices and sent a clear message to Plaintiff and other Hispanic
employees of the Fort Collins Police Department that complaints against Sgt. Shaklee are futile
and that there would be severe adverse consequences suffered by those who made complaints
against Defendant Shaklee or provided evidence in support of the same.
12. In doing so, the City of Fort Collins and Defendant Vagge ratified the unlawful
actions of Sgt. Shaklee and validated the concerns of the Plaintiff and other Hispanic employees
of the Police Department, that Sgt. Shaklee’s discriminatory and retaliatory practices were
reflective of a policy and practice of the Fort Collins Police Department, a policy and practice
that had existed long before the Plaintiff was singled out as the next target of Sgt. Shaklee’s
racial bias.
13. The actions of Defendant City of Fort Collins, as more particularly described
herein, are reflective of a defacto policy, custom and practice of the City which permits,
condones, or otherwise encourages discrimination by supervisors of the Fort Collins Police
Department based upon race and/or national origin and which further allows such supervisors, in
this case Sgt. Shaklee, to retaliate against those who complain against such practices or who
provide information or evidence in support of such complaints.
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14. All actions of Defendant Vagge, as more particularly described herein, were
undertaken within the course and scope of his employment as a Deputy Chief of Police of the
Fort Collins Police Department and under color of law. All actions of Defendant Vagge were
undertaken by the Defendant individually and as a final policy maker for the Fort Collins Police
Department.
15. All actions of Defendant Gary Shaklee, as more particularly described herein,
were undertaken by Defendant Shaklee individually and were reflective of Defendant Shaklee’s
conformity with a long standing practice of discrimination based upon race, which had been
condoned, permitted or otherwise encouraged within the agency. Defendant Shaklee’s conduct,
as more specifically described herein, was undertaken within the course and scope of his
employment as a supervisor in the Fort Collins Police Department and under color of law.
III. JURISDICTION AND VENUE
16. Jurisdiction of this Court is invoked under 28 U.S.C. §§ 1331 and 1343. This
action is authorized and instituted under Title VII of the Civil Rights Act of 1964, as amended,
42 U.S.C. § 2000e, et seq. and 42 U.S.C. § 1981.
17. Venue is proper in this Court pursuant to 28 U.S.C. § 1391(b) and 42 U.S.C. §
2000e-5(f)(3) because of unlawful employment practices alleged herein were committed within
the jurisdictional boundaries of the United States District Court for the District of Colorado.
18. All procedural prerequisites for filing this lawsuit have been met. Plaintiff timely
filed a Charge of Discrimination alleging race discrimination, national origin and retaliation
against the City of Fort Collins and Sgt. Shaklee with the Equal Employment Opportunity
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Commission (“EEOC”) and subsequently requested a Notice of Right to Sue letter. A right to
sue letter was issued on February 2, 2016. This Complaint and Jury Demand is being filed
within ninety (90) days of receiving the Notice of the Right to Sue from the EEOC. Therefore,
under 42 U.S.C. § 2000e-5(f)(1), Plaintiff has satisfied all procedural prerequisites for suing in
federal court.
IV. GENERAL ALLEGATIONS
A. Background
19. Sgt. Shaklee was initially assigned to the Northern Colorado Drug Task Force as a
Detective in approximately 2004. Shortly after being assigned to the unit, Sgt. Shaklee was
removed from the unit due to the complaints of a Hispanic female employee.
20. During his initial tenure in the drug task force, Defendant Shaklee’s then
supervisor, a Hispanic male, noted several instances where it appeared that Detective Shaklee
had singled out Hispanic employees for scrutiny and unwarranted criticism, leading to several
such employees, including the Hispanic female referenced above, to leave the unit or quit their
employment entirely.
21. One of the practices noted by Defendant Shaklee’s supervisor in the drug task
force, was Shaklee’s habit of falsely claiming that he had received complaints from other
employees or civilians about a Hispanic employee when no such complaints had been made.
Defendant Shaklee would then go to his supervisors, including Defendant Vagge, and claim that
he had received a Complaint, thereby, causing the Hispanic employee to be investigated.
Defendant Shaklee’s supervisor memorialized his concerns in Defendant Shaklee’s performance
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evaluations, which evaluations were reviewed and approved by Defendant Shaklee’s chain of
command, which included Defendant Vagge.
22. Defendant Shaklee’s supervisor also reported the above described concerns to the
City of Fort Collins Human Resources employee Lori Greening, who interviewed Defendant
Shaklee’s supervisor regarding his concerns. This Sergeant pointed out Defendant Shaklee’s
pattern of targeting individuals with Hispanic surnames for adverse employment action.
23. Defendant Shaklee’s supervisor also pointed out Defendant Shaklee’s repeated
false complaints against him personally, which he perceived to have been in retaliation for
having Defendant Shaklee removed from the task force shortly after he was originally assigned
there, as the result of his discrimination against a Hispanic female employee.
24. Defendant Vagge and Defendant Shaklee were also the subjects of a similar
complaint by yet another Hispanic supervisor, a Hispanic Lieutenant, in 2010. Defendants
Vagge and Shaklee had this Hispanic supervisor removed from the Task Force within a short
period of time of him being assigned to the unit.
25. Like other Hispanic employees before him, this supervisor filed a Complaint of
discrimination against Defendants Vagge and Shaklee, which complaints were also investigated
by Lori Greening of the City of Fort Collins Human Resources Department. One of the common
threads among these complaints was Sgt. Shaklee’s repeated characterizations of Hispanic
employees as “lazy and incompetent”, an obvious racial stereotype.
26. While Ms. Greening ultimately did not find that Defendants actions were
discrimination, Ms. Greening is purported to have made numerous recommendations to address
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disparate treatment issues, which recommendations, upon information and belief, were ignored
by Defendant Vagge and the City of Fort Collins.
27. Approximately 6% of the employees of the Fort Collins Police Department are
Hispanic. Hispanics make up approximately 14% of the population of the City of Fort Collins.
28. Upon information and belief, the former Human Resources Director of the City of
Fort Collins, also expressed concerns about Defendant Vagge and Defendant Shaklee targeting
Hispanic employees for adverse employment action, harassment designed to secure th e
resignations of Hispanic employees and their practice of retaliating against those who
complained about such practices or who supported complaints of discrimination to no avail. No
action was taken by Defendant Fort Collins or Defendant Vagge to address these issues.
29. Over the past decade, 2 independent surveys were conducted of Fort Collins
Police Department employees. Dr. Kim Miller conducted a survey on behalf of Lodge 3 of the
Fraternal Order of Police. The results of this survey were highly critical of Defendant Vagge’s
management style and his practice of targeting employees and allowing others to do so. The
City then conducted its own survey, which validated Dr. Miller’s results in all respects. A prior
survey, conducted by Dr. Jack Digliani, resulted in similar findings. Nevertheless, Defendant
City took no action to address these concerns.
30. Indeed, notwithstanding the results of these surveys and multiple complaints by
Hispanic employees that they had been targeted for harassment and subjected to disparate
treatment, false complaints and harassment by Defendants Vagge and Shaklee, to say nothing of
the concerns expressed by the City’s own Human Resources department, Defendant City took no
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action. It is notable here that Defendant Shaklee is currently under consideration for promotion
to the rank of Lieutenant.
B. Discrimination and Retaliation Against Plaintiff Araujo by Defendant
Shaklee and Defendant Vagge and the City of Fort Collins
31. Plaintiff Araujo was assigned to the Northern Colorado Drug Task Force in
February of 2012. This was a “special assignment”, offered only to those officers whose
previous performance was outstanding.
32. Defendant Shaklee was a Sergeant in the Drug Task Force Unit, and almost
immediately upon Plaintiff’s assignment to the Unit, began treating Plaintiff differently from the
Caucasian members of the unit, holding him to a different standard, singling him out for
criticism when his performance was no different from that of Caucasian members of the unit,
giving him less favorable assignments, denying him favored assignments that he was qualified
for, making sarcastic and demeaning public remarks about him, and engaging in other conduct
designed to make Plaintiff request a transfer from the unit.
33. When Sgt. Shaklee’s efforts proved unsuccessful, in early 2014, Sgt. Shaklee
initiated an investigation against Plaintiff, purportedly based upon 3 complaints Shaklee had
purportedly received from Plaintiff’s co-workers about his report writing.
34. Prior to his assignment to the Task Force, Plaintiff had volunteered to assist other
Fort Collins Police Department employees as a Spanish and Portuguese interpreter. After
arriving at the Task Force, Plaintiff was told by Sgt. Shaklee that his volunteer work as an
interpreter was a “waste of time”.
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35. As noted above, in early 2014, Sgt. Shaklee alleged that he had received
complaints from 3 police department employees regarding Plaintiff’s report writing, specifically
associated with cases in which he had acted as an interpreter.
36. Defendant Shaklee falsely claimed that he had received a complaint from Sgt.
Kristy Volesky regarding Plaintiff’s alleged failure to complete a report an d document his
actions as an interpreter when he assisted Detective Koby Northern in an investigation. No such
complaint had been made, yet Sgt. Shaklee investigated it and sustained Plaintiff for a policy
violation.
37. Sgt. Shaklee also alleged that another Detective had made a similar complaint, an
allegation which was also false.
38. As to the third complaint, Defendant Shaklee alleged that this complaint had been
made by his wife, Detective Jaclyn Shaklee. In fact, no such complaint had been made, yet
despite a policy prohibition against Sgt. Shaklee investigating a matter in which his wife was
involved, Sgt. Shaklee fabricated these 3 alleged complaints, then sustained his own false
complaints and issued Plaintiff a Written Reprimand on May 28, 2014, which was not served on
Plaintiff until July 1, 2014.
39. During this “investigation” by Sgt. Shaklee, Plaintiff attempted to explain that his
duties as an interpreter asked to report on an interview he conducted on behalf of a Detective
were far different from those he prepares as an investigator. Plaintiff provided Defendant
Shaklee legal distinctions between these two roles, which authority Defendant Shaklee ignored.
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40. At the same time, many of the other Caucasian members of the Task Force were
also occasionally late in turning in reports. None of these other Caucasian employees were
subjected to criticism from Sgt. Shaklee, nor were they investigated or subjected to discipline by
Sgt. Shaklee despite having engaged in the same conduct which led to the issuance of a Written
Reprimand to Plaintiff. Such disparate treatment was due to Plaintiff’s race. During his self-
appointed “investigation” and in his subsequent meetings with Plaintiff, Defendant Shaklee
referred to Plaintiff as “lazy and incompetent”, a phrase which Sgt. Shaklee reserves to describe
Hispanic employees with whom he has issues.
41. In response to the Written Reprimand, Plaintiff filed a Grievance pursuant to Fort
Collins Police Department policy and procedure, complaining that Defendant Shaklee had
fabricated the complaints, initiated an investigation of his own false complaints and had
investigated an alleged complaint of his wife, despite a policy which prohibited such conduct, all
predicated upon Hispanic heritage.
42. Immediately after Plaintiff filed his Grievance, Sgt. Shaklee caused to be issued a
memorandum citing numerous false “Performance Issues” of the Plaintiff and suspending him
from all collateral duties including off-duty work, undercover assignments and on-call. These
actions were taken by Defendant Shaklee and permitted by the other Defendants, in retaliation
for Plaintiff’s initiation of a Grievance against Sgt. Shaklee and in an effort to discourage
Plaintiff and other employees from bringing forward complaints regarding Defendant Shaklee’s
discriminatory and disparate treatment against Hispanic employees.
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43. Ultimately, Plaintiff was required to file a formal Internal Affairs Complaint
against Defendant Shaklee. While Defendant Vagge and others in Defendant Shaklee’s chain of
command sustained certain minor policy violations against Sgt. Shaklee, Defendant Vagge and
the City of Fort Collins determined that Shaklee’s multiple false statements, as established by the
investigation, were nothing more than inadvertent mistakes. Thus, no meaningful action was
taken against Sgt. Shaklee for the conduct more specifically described herein. These actions
were reflective of a policy, custom and practice of Defendant Vagge and Fort Collins to allow
and encourage Sgt. Shaklee’s discriminatory and disparate treatment of Hispanic employees, his
harassment of Hispanic employees and his practice of retaliating against Hispanic employees and
others who complained about Defendant Shaklee’s discriminatory practices.
V. CLAIMS FOR RELIEF
FIRST CLAIM FOR RELIEF
RACE AND NATIONAL ORIGIN DISCRIMINATION IN VIOLATION OF TITLE VII
44. Plaintiff incorporates by reference all paragraphs of this Complaint as if fully set
forth herein.
45. During Mr. Araujo's employment, Defendant engaged in unlawful discriminatory
employment practices by discriminating against him with respect to the terms and conditions of
his employment based on his race (Hispanic) and national origin (Brazilian).
46. The unlawful employment practices include, without limitation, disparate
treatment, unwarranted discipline, and constructive discharge because of Mr. Araujo’s race and
national origin.
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47. The effect of these practices deprived Mr. Araujo of equal employment
opportunities and otherwise adversely affected his employment status because of his race and
national origin.
48. These unlawful employment practices were intentional.
49. The unlawful employment practices were undertaken with malice or with reckless
indifference to Mr. Araujo’s federally protected rights.
SECOND CLAIM FOR RELIEF
RETALIATION FOR ENGAGING IN PROTECTED ACTIVITY UNDER TITLE VII
50. Plaintiff incorporates by reference all paragraphs of this Complaint as if fully set
forth herein.
51. Mr. Araujo had a good faith belief that the Defendants were engaged in
discriminatory conduct in violation of Title VII.
52. Mr. Araujo engaged in protected opposition to Defendants’ unlawful employment
practices by complaining about discrimination.
53. In retaliation for Mr. Araujo’s opposition to what he reasonably believed to be
Defendant Shaklee's unlawful discrimination against him, Defendant Shaklee disciplined the
Plaintiff and created such a hostile and oppressive work environment that Plaintiff was
compelled to resign from his employment.
54. The effect of these practices deprived Mr. Araujo of equal employment
opportunities and otherwise adversely affected his employment status because of his national
origin.
55. These unlawful employment practices were intentional.
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56. The unlawful employment practices were done with malice or with reckless
indifference to Mr. Araujo’s federally protected rights.
THIRD CLAIM FOR RELIEF
DISCRIMINATORY TREATMENT BECAUSE OF RACE
IN VIOLATION OF SECTION 1981
57. Plaintiff incorporates by reference all paragraphs of this Complaint as if fully set
forth herein.
58. During Mr. Araujo’s employment, the Defendants engaged in unlawful
discriminatory employment practices by discriminating against him with respect to the terms and
conditions thereof.
59. The unlawful employment practices include, without limitation, disparate
treatment, discipline, and harassment, false accusations and unwarranted investigations all
because of Mr. Araujo’s race (Hispanic).
60. The effect of these practices deprived Mr. Araujo of equal employment
opportunities and otherwise adversely affected his employment status because of his race.
61. These unlawful employment practices were intentional.
62. The unlawful employment practices were done with malice or with reckless
indifference to Mr. Araujo’s federally protected rights.
FOURTH CLAIM FOR RELIEF
RETALIATION FOR ENGAGING IN PROTECTED ACTIVITY UNDER §1981
63. Plaintiff incorporates by reference all paragraphs of this Complaint as if fully set
forth herein.
64. Mr. Araujo had a good faith belief that the Defendants were engaged in
discriminatory conduct in violation of§ 1981.
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65. Mr. Araujo engaged in protected opposition to the Defendants’ unlawful
employment practices by complaining about discrimination.
66. In retaliation for Mr. Araujo’s opposition to what he reasonably believed to be
Defendant Shaklee’s unlawful discrimination against him, Defendant Shaklee investigated,
disciplined, publically humiliated, chastised and harassed the Plaintiff, resulting in Plaintiff’s
separation from his employment.
67. The effect of these practices deprived Mr. Araujo of equal employment
opportunities and otherwise adversely affected his employment status because of his Hispanic
race and national origin (Brazilian).
68. These unlawful employment practices were intentional.
69. The unlawful employment practices were done with malice or with reckless
indifference to Mr. Araujo’s federally protected rights.
FIFTH CLAIM FOR RELIEF
FAILURE TO TRAIN OR SUPERVISE UNDER § 1981
70. Plaintiff incorporates by reference all paragraphs of this Complaint as if fully set
forth herein.
71. Defendant Fort Collins and Defendant Vagge developed and maintained
employment related policies, procedures, customs, and/or practices exhibiting or resulting in
deliberate indifference to the protected Federal rights of Hispanic employees of the City of Fort
Collins Police Department, which proximately caused the violation of Plaintiffs’ Federal rights.
72. Defendant Fort Collins and Defendant Vagge maintain employment related
policies, procedures, customs, and/or practices that tacitly or explicitly authorize discrimination
and retaliation against the protected class of Hispanic employees by supervisors of the Fort
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Collins Police Department, including, but not limited to, the failure to properly train on at least
the following: proper supervision, internal investigations, grievances, discipline, and Title VII
issues and the rights of employees with respect to the same.
73. In light of being a municipal employer, the need for specialized training and
supervision is so obvious, and the inadequacy of training and/or supervision is so likely to result
in the violation of Federal rights such as those described herein.
74. Defendants Fort Collins and Vagge are liable for their failure to train and
appropriately supervisor the employees of the Fort Collins Police Department.
75. The inadequate training and supervision provided by Defendants Fort Collins and
Vagge resulted from a conscious or deliberate choice to follow a course of action from among
various alternatives available to Fort Collins.
76. If any training was given to Defendant Shaklee concerning supervision, internal
investigations, grievances, discipline, and Title VII issues and the rights of employees,
Defendants Fort Collins and Vagge knew or should have known that such training was reckless
or grossly negligent and that misconduct in that area was almost inevitable.
77. Defendants Fort Collins and Vagge had a duty to protect the Federal rights of the
employees of the Fort Collins Police Department.
78. As a direct and proximate cause and consequence of Defendants Fort Collins and
Vagge’s failure to train and supervise, Plaintiff suffered injuries, damages, and losses as set forth
above.
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WHEREFORE, Mr. Araujo respectfully requests that the Court enter judgment in his
favor and against the Defendants, and award the following relief, to the fullest extent allowed by
law:
a. Back pay and related compensation, and front pay, in amounts to be determined at
trial;
b. Compensatory and consequential damages, as allowed;
c. Emotional distress damages, as allowed;
d. Punitive damages, as allowed;
e. Injunctive and/or declaratory relief:
f. Pre-judgment and post-judgment interest at the highest lawful rate;
g. Attorneys' fees and costs of this action, including expert witness fees, as
appropriate; and
h. Any such further relief as justice allows.
PLAINTIFF DEMANDS A JURY TRIAL ON ALL ISSUES SO TRIABLE.
Dated this 29th day of April, 2016.
Respectfully submitted,
s/ Marc F. Colin
Marc F. Colin
BRUNO, COLIN & LOWE, P.C.
1999 Broadway, Suite 4300
Denver, Colorado 80202
Tel: (303) 831-1099
Fax: (303) 831-1088
E-mail: mcolin@brunolawyers.com
Attorney for Plaintiff Kennyberg Araujo
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