Three Officers Sue Fort Worth, Chief Halstead
Three Officers Sue Fort Worth, Chief Halstead
Three Officers Sue Fort Worth, Chief Halstead
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)
)
)
)
Plaintiff,
)
)
vs.
)
)
CITY OF FORT WORTH,
)
JEFFREY HALSTEAD, individually )
and in his official capacity of Chief )
of Police of the Fort Worth
)
Police Department,
)
)
Defendants.
)
No.:___________________
JURY TRIAL DEMANDED
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Fort Worth, Tarrant County, Texas and performed work for Fort Worth in
Fort Worth, Texas during the time period giving rise to the claims in this
litigation.
2.
3.
Halstead was, and at all times relevant to this action was, the
jurisdiction.
5.
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or about May 16, 2010 Edney was assigned as the Lieutenant over the
Traffic Division Investigation Section at 1100 Nashville.
During this
time, Lt. Whit Boyd was over the Traffic Enforcement Section that worked
out of 5000 Martin Luther King (MLK) Freeway.
7.
treasured every day to be working in a job that made him very happy. That
changed the day that a fellow Police Officer Sergeant Delbert Johnson,
who was assigned to Lieutenant Boyd in the Traffic Enforcement Section,
informed Lt. Edney that he wanted Lt. Edney to see a picture. Lt. Edney
went to the MLK facility and met with Sergeant Johnson. He showed Lt.
Edney an offensive picture of Sgt. Ann Gates holding a noose around a
snowmans neck with a police cap on his head and a banana in his hand.
As African-Americans, both Lt. Edney and Sgt. Johnson were offended by
the connotations that picture brought up. Sergeant Johnson advised that he
had entered into his office and found the picture lying on his desk. The
picture was taken outside of 5000 MLK Freeway at the Traffic
Enforcement Section.
8.
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was created for the Step Grant to streamline rules and regulations.
Captain B. Sudan and Lt. Edney both felt that Sergeant Johnson would be
the best person to supervise the Step Grant due to his ability to pay
attention to detail and strong record keeping skills. Sergeant Johnson had
been audited by SIU and TXDOT and our own Grants Division and all
have commented that he is doing an excellent job.
12.
office asking for assistance with an argument he was having with Sergeant
Stamp that was getting out of control. Lt. Edney went with Sergeant
Thome to meet with Sergeant Stamp. Lt. Edney advised both Sergeants
that he wanted to see them in his office. Once in his office Lt. Edney gave
both sergeants a verbal Coach and Counseling Session. At the conclusion
of the meeting both sergeants agreed to get along with one another.
Captain Sudan was also informed of the situation and advised both
sergeants that if the conflict continued someone would be transferred.
13.
Mission to help free up patrol. This mission stated that traffic officers
would begin to help with all traffic accidents, allowing patrol to answer
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Sergeant Delbert Johnson asked Lt. Edney to join him and Officer Karl K.
Hodge in the Nashville parking lot. Officer K. Hodge advised that Sergeant
Stamp sent an anonymous complaint to the Special Investigation Unit
(SIU) on Sergeant D. Johnson claiming that he was stealing from and
abusing the Step Grant.
anonymous person, just three days later, Sgt. Stamp told investigators in
the Special Investigation Unit (SIU) that he had sent it and that he would
help in any way possible in their investigation of Sgt. Johnson.
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There were a lot rumors around the Traffic Division that the
three sergeants complained that Lt. Edney was going to lunch with Major
Jones as well as other unfounded negative untruthful things that were
damaging the reputation of Lt. Edney.
from the secret meeting that took place between Sergeant Stamp,
Sergeant Gates, Sergeant Cagle and Chief Halstead.
The dishonest
information was being said so that action could be taken against Lt. Edney
and Deputy Chief Jones.
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after he became Captain over traffic, and Captain Salinas advised that he
was upset with Lt. Edney because Lt. Edney sent an email to Deputy Chief
Jones and only cc'd him. Lt. Edney then reminded Captain Salinas that Lt.
Edney was acting Captain during that time the email was sent, and only
cc'd him to keep him abreast on what was going on in his division.
Captain Salinas then informed Lt. Edney that Chief Halstead placed him
over traffic to evaluate Lt. Edney and other people so he could determine
the problem and transfer those that needed to be transferred.
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him that he had a meeting with Chief Halstead and during this meeting
Chief advised him that Lt. Edney had failed him as a supervisor, and
everything that was happening to Sergeant Johnson was Lt. Edneys fault.
Sergeant Johnson advised the Chief that Lt. Edney did not fail him, but
Captain Sudan did. Chief Halstead stated that he was going to transfer Lt.
Edney immediately out of the Traffic Division. Sergeant Johnson told the
Chief that if he did that he would be doing a grave injustice to Lt. Edney
and the Traffic Division. The Chief later recanted his statement and said
not to tell Lt. Edney anything about the transfer because he may do
something different. However, towards the end of Lt. Edneys vacation he
was notified by Sergeant Johnson that Captain Salinas was interviewing
Lieutenants for Lt. Edneys position. At that point, Lt. Edney had still not
been made aware by any of his commanders of a transfer.
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Assistant Chief Pridgen on July 10, 2013. During this meeting Lt. Edney
advised Chief Pridgen that he heard rumors that he was being transferred
and wanted to know if the rumors were true. Chief Pridgen advised Lt.
Edney that Captain Salinas wanted him transferred. When asked what he
had done to be transferred, Chief Pridgen stated that Lt. Edney had not
Plaintiffs Original Petition
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Lt. Edney became upset because he has been with the Fort
Worth Police Department for twenty eight years and had received
distinguished evaluations since he had been in Traffic. Lt. Edney was also
nominated for Commander of the year by Captain Sudan in 2011 and 2012.
Even though Lt. Edney requested, he received no documentation from
Captain Salinas regarding why he was being transferred. Without the
proper documentation, you cannot transfer a Lieutenant.
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on July 18, 2013, Lt. Edney met with Captain Salinas, Deputy
Chief Jones, Assistant Chief Pridgen and Sergeant Gutter who sat as a
witness inside of a conference room at 350 W. Belknap. Assistant Chief
Pridgen opened up the meeting by stating that Captain Salinas would
advise why he wanted Lt. Edney transferred. Captain Salinas said he
wanted a Lieutenant that would be loyal to him, and Lt. Edney was not
loyal to anyone but Deputy Chief Jones. This statement; however, was
untrue as Captain Salinas and Lt. Edney have been friends for more than
27 years. Captain Salinas also stated that he wanted to be able to pick his
own Lieutenant, because he wanted to go in a different direction. During
our meeting Captain Salinas advised that the talk about transferring Lt.
Edney came about after an All Staff Meeting that occurred on or around
June 27, 2013. Chief Halstead met with Captain Salinas and Assistant
Chief Pridgen advising them that he wanted Lt. Edney transferred out of
the unit. In addition, Chief Halstead advised Captain Salinas that he could
start looking for a new lieutenant as soon as possible.
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Salinas interviewed. On July 11, 2013 Lieutenant Hawkins came into Lt.
Edneys office at the Traffic Division and advised Lt. Edney that during
her interview with Captain Salinas he was saying negative things about Lt.
Edney. She stated that he blamed Lt. Edney for the lack of documentation
on the "Snowman" incident and advised her that the last straw for him
making the decision to get Lt. Edney out of the unit was because Lt. Edney
did not attend Sergeant A. Gates retirement party which is not a General
Order violation.
25.
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when he transferred him out of the Traffic Division to Patrol. This transfer
changed Lt. Edneys work schedule from day shift 9:00 a.m. to 5:00 p.m.
Monday through Friday to the 5:00 a.m. to 3:00 p.m. shift and while before
the transfer, Lt. Edney didnt work weekends or holidays, he was now
required to work every weekend and every holiday.
In addition, Lt.
Edneys take home vehicle was taken away. This was a punch to Lt.
Edneys gut, completely changing the quality of his and his familys
personal lives and likewise severely impacting the amount of
compensation he was making because he no longer got overtime hours that
he had been receiving when he was in Traffic. Additionally, the transfer
and shift change resulted in the loss of a part-time secondary job that he
held, costing Lt. Edney thousands of dollars in lost income. All told, the
amount Lt. Edney lost in income was over $30,000.00.
27.
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Days after the meeting with Mr. Daniels, Sgt. Dalco and Sgt.
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Daniels. Sgt. Hudson was asked to hand over his personal cell phone to IA
for the collection of additional data to determine if Meet and Confer
violations had occurred. This was requested even though no personnel had
filed a complaint and Sgt. Dalco and Sgt. Hudson were both interrogated.
Subsequently, Fort Worth police chief Halstead was informed by IA that
no Meet and Confer violations had occurred. In spite of this knowledge,
Chief Halstead order another white police officer to file a complaint with
IA so that he could continue the IA investigation based on ill will
because Sgt. Dalco and Sgt. Hudson were African-Americans. Chief
Halstead has a history of discrimination in the department as it relates to
disparate treatment of African-American officers or transferring them at
will.
31.
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manager stating the Meet and Confer contract is between the Fort Worth
Police Officers Association and the City Manager.
There were no
FWPD were so out of control that the leaders of the Fort Worth Black
Police
Officers
Association
filed
complaints
alleging
race-based
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The Coleman Report (Coleman) came out late last year. After
a thorough investigation, Coleman found that the FWPD had tolerated and
allowed a hostile work environment over a three year time period that was
based in part on race and retaliation for Lt. Edneys, Sgt Hudsons and Sgt.
Dalcos prior complaints of race discrimination and harassment. This was a
highly publicized report that generated many news reports. It also resulted
in the extraordinary measure of Chief Halstead publicly apologizing for the
racial and retaliatory animus that was so pervasive within the Department.
In the video that was posted on YouTube, Chief Halstead admitted that
Sgt. Johnson and Lt. Edney specifically and others generally were
discriminated against because of the color of their skin.
34.
Chief Halstead order a white police officer to file a complaint with IA that
Sgt. Dalso and Sgt. Hudson violated the Meet and Confer order, even
though there was no supporting documentation or validity to the fact that
the meeting that Sgt. Dalco and Sgt. Hudson attended with the assistant
city manager was in violation of the Meet and Confer contract.
Moreover, Chief Halstead had already been made aware by IA that there
was in fact no violation of the Meet and Confer contract. Chief Halstead
ordered this IA investigation because Sgt. Dalco and Sgt. Hudson were
Plaintiffs Original Petition
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African American.
35.
Dalco and Hudson, Chief Halstead began to retaliate against Sgt. Dalco
and Sgt. Hudson by having meetings with non-African American Officers
and began to create a hostile work environmental against Sgt. Dalco and
Sgt. Hudson.
36.
harassment, and retaliation has taken a severe emotional toll on Lt. Edney
and his family. The emotional distress and mental anguish he has suffered
is significant to say the least.
38.
and retaliation it has taken a severe emotional toll on Sgt. Hudson and his
family. Sgt. Hudson has lost countless hours of sleep and has lost a lot of
Plaintiffs Original Petition
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weight while enduring this discrimination. Sgt. Hudson became the subject
of personal attacks and insults. As a result of Chief Halsteads failure to
publically disclose his misuse of internal affairs to investigate Sgt. Hudson,
very distinct racial lines were drawn within the department. Sgt. Hudson
has received numerous threats, insults and personal attacks based on the
actions of Chief Halstead. Every day that Sgt. Hudson has to come to
work hes looking over his shoulder and wondering what is going to
happen to him each day. Sgt. Hudson has been personally attacked in
person as well as on law enforcement social media pages. Sgt. Hudson is
afraid for not only himself but also his family. Sgt. Hudson has lost 28
pounds throughout this ordeal with the Chief Halstead, and has recently
been clinically diagnosed with major depression, anxiety and ulcerative
colitis. Chief Hallstead created a racially hostile work environment. Sgt.
Hudson was also retaliated against for standing up for his rights and the
rights of other minority officers within the department.
39.
Sgt.
Dalco has been humiliated by Chief Halstead and has been made to endure
racial comments. Sgt. Dalcos ability to supervise has been affected as he
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has been labeled and trouble maker and has suffered through a hostile work
environment.
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a.
Actual damages;
b.
c.
Punitive damages;
d.
e.
f.
g.
Plaintiffs Original Petition
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