Case 2:15-cv-01320-MSG Document 1 Filed 03/16/15 Page 1 of 16

IN THE UNITED STATES DISTRICT COURT FOR

THE EASTERN DISTRICT OF PENNSYLVANIA
BARRY DELAGOL

: NO.

vs.

: CIVIL ACTION

CHARLES RAMSEY , CITY OF PHILDEPHIA, and

THREE JOHN AND THREE JANE DOES

: JURY TRIAL DEMAND

:

COMPLAINT
I.

INTRODUCTION
1.

Plaintiff Barry Delagol brings this civil action for intentional invidious gender and

race discrimination by the defendants against the Plaintiff under 42 USC 1983 for a deprivation
under color of state law of Plaintiffs Fourteenth Amendment equal protection and due porcess
rights as secured by the United States Constitution. Plaintiff brings a direct action under the
equal protection Articles of the Commonwealth of Pennsylvania Constitution. Plaintiff seeks a
jury trial and the a ward of all relief the law and/or equity allows to make the Plaintiff whole
under the circumstances; such relief as, but not limited to compensatory, consequential, nominal,
actual, and special or punitive damages, reasonable attorney fees, litigation costs, and
reinstatement to employment as a police officer with any and all promotional or employment
opportunities existing following the Plaintiffs termination, which he might have been available
for but was not made available to the Plaintiff due to the wrongful race/gender based
discriminatory termination by defendant Charles Ramsey and/or the City of Philadelphia, and/or
a Doe defendant.
2.

The relief Plaintiff seeks is provided under The 1964 Civil Rights Act, (42 U.S.C.

1983 et seq.) and to include but not limited to Section 1988, for a deprivation under color of
state law of equal protection rights and the prohibition of discrimination because of race and
gender.
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3.

The relief Plaintiff also seeks is permitted under the laws of and to include the

Commonwealth of Pennsylvania Constitution, allowing for equitable, compensatory and actual

damage relief.
4.

The law prohibiting discrimination because of race and gender was clearly

established at the time of the Defendants acts, action and/or omission(s) to act. The Defendants
action was intentional, malicious, a violation of law and done for independent and joint personal
reasons to discriminate against whites and males under a policy practice or custom of the City of
Philadelphia to treat differently white and males when they are in similar circumstances as
minority males and female persons. When the defendants acted against the Plaintiff the
Defendant knew they would deprive the plaintiff of protected constitutional rights, case injury or
damages to the Plaintiff, or likely would cause injury or damages and/or a deprivation to the
Plaintiffs Constitution, legal or regulatory rights as secured by federal and state law.
5.

As is more fully set forth below in detail, the Defendants, for themselves, the

group and at all times related to the Plaintiffs claims that are raised in this complaint, acted
independent and jointly with one another, for a personal or group goal, under color of state law,
by virtue of their governmental employment or being a governmental entity, to achieve a
common goal for a legitimate reason through illegitimate means, or an illegal purpose with
legitimate means.
6.

The Defendant at all times relevant to the Plaintiff claims acted intentionally,

recklessly, maliciously, with gross negligence, and in reckless disregard of and/or in deliberate
indifference to the Plaintiffs rights and in violation of the law prohibiting race and/or gender
based discrimination.

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7.

The Defendants at all times related to the claims raised in the complaint, knew or

were on notice that their conduct would result or likely result in a deprivation of federally
protected rights, of rights guaranteed under Commonwealth law and Constitution, and that their
conduct would subject them to liability under the law and include but not limit the law to The
Civil Rights Act of 1964 (42 U.S.C. 1983 et seq.).
8.

As is more fully set forth below in detail, the Defendants while acting under color

of state law and a policy, practice or custom, which is more fully identify below in detail and
includes a failure to supervise and/or train its employees which omission would or likely would
lead to a deprivation of rights, intentionally recklessly, maliciously, and/or in reckless disregard
or deliberate indifference of Plaintiff's rights deprived the Plaintiff of said constitutional and
statutory rights as are secured by law and constitution; such rights as: the rights to free speech,
petition clause, due process, and equal protection.
II.

JURISDICTION / VENUE

9.

Jurisdiction for the District Court to hear this action is afforded to the District

Court pursuant to 42 U.S.C. 1983 et seq., The Civil Rights Act of 1964, its amendments and
under 28 U.S.C. 1331 (Federal Question) and 28 U.S.C. 1343 (3) and (4) (Civil Rights).
10.

Venue properly lies in the United States District Court for the Eastern District of

Pennsylvania because Plaintiffs causes of actions herein pleaded accrued in; the acts occurred
in, and the defendants reside in Philadelphia County which is the venue established for the
District Court for the Eastern District of Pennsylvania.

Plaintiff invokes supplemental

jurisdiction under 28 U.S.C. 1367 so the District Court can resolve all concurrent state
ancillary, pendent or supplemental claims.

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III.

PARTIES

11.

Barry Delagol is the Plaintiff, he resides in Bucks County and he is a white male

and former 15 year service City of Philadelphia Police officer.

12.

Charles Ramsey is Defendant Ramsey, and he is believed to maintain a residence

in Philadelphia County, Commonwealth of Pennsylvania. Ramsey is currently the City of

Philadelphia Police Commissioner and has been since 2008.
13.

The City of Philadelphia is an incorporated City of the First Class, it is a Home

Rule Charter political subdivision of the Commonwealth for Pennsylvania.

14.

The City acts though the Acts, Policies, Rules, Ordinances, and Laws from the

action of the General Assembly of the Commonwealth of Pennsylvania, Congress of the United
States, City of Philadelphia Council, and heads offices that are elected and/or appointed to City
Departments and positions such as but not limited to the Mayor, City Counsel, Police and Fire
Commissioners or other Heads of City Departments.
15.

The three John and Jane Does identities are not known specifically by the

Plaintiff; however, Plaintiff believes the Does are official of the City of Philadelphia who are
natural person and are African-American.
IV.

MATREIAL FACTS
16.

On or about May 7, 2013 the Plaintiff was terminated from employment as a City

of Philadelphia police officer.

17.

Plaintiff on or about October 1997 was hired by the City of Philadelphia as a

police officer, and as such Plaintiff obtained employment were the employment could not be
ended without just cause or in violation law or constitutional right.

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18.

Plaintiff at the time of termination had 15 years service with the City of

Philadelphia Police Department; further, Plaintiff had no disciplinary history, and he was
assigned to the K-9 Unit where he was gifted a dog by the City.
19.

Plaintiff was terminated for alleged on-duty sexual misconduct with a female.

20.

Plaintiffs dog (property) was removed from him on direction of a Doe, Ramsey

and the City. The property was taken from Plaintiff without cause, and/or valid or adequate due
process of law.
21.

Defendant Charles Ramsey is the person that terminated the Plaintiff from

employment.
22.

Ramsey is the Police Commissioner and he was the Police Commissioner when

Plaintiff was terminated.

23.

Charles Ramsey acted under color of state law to terminate the Plaintiff. Indeed,

to terminate the Plaintiff on or about May 2013, Charles Ramsey used the title, authority and
powers of the City of Philadelphia Police Commissioners Office.
24.

Charles Ramsey is now, and was when Plaintiff was terminated, the highest

ranking decision-making, policy-making official within the City of Philadelphia Police

Department.
25.

Defendant Ramsey did not use any established method to weigh the gravity of the

allegation facts for determination what might be the punishment on the alleged misconduct.
26.

Defendant Ramseys decision to terminate Plaintiff was arbitrary, capricious, and

shocks the conscience when compared to prior decision by Ramsey and the City of Philadelphia
to not terminate employees of color or other minority status and gender for substantially similar
conduct.

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27.

The City of Philadelphia supported and upheld Charles Ramseys decision and act

to terminate the Plaintiff from employment as a police officer on the allegation the Plaintiff had
engaged in sexual misconduct with a female while on duty.
28.

Plaintiff believes and therefore asserts that Mayor Michael Nutter, Deputy Mayor

Everett Gillison, and others within the City Administration, that may make policy or are final
decision-makers also, reviewed Charles Ramseys action to terminate the Plaintiff, and they
either acquiesced to the decision and basis for it, or they chose to support and uphold Charles
Ramseys decision and basis for the City of Philadelphia to terminate the Plaintiff under the
allegation of sexual misconduct on duty with a female.
29.

Mayor Nutter, Deputy Everett Gillison, and other Heads of City Departments that

reviewed, and/or either acquiesced or supported Charles Ramseys termination of the Plaintiff,
are not white but African American and all have authority to stop the Plaintiffs termination or
reinstate the Plaintiff.
30.

Others that are or were similarly situated as the Plaintiff but who are not white

were not terminated from employment with the City by the City of Philadelphia or Charles
Ramsey, when these others were alleged to have engaged in sexual misconduct with a female
while on duty.
31.

Jerold Bates is a police employee and African American. Bates is alleged to have

engaged in sexual conduct with the female employee. Bates admits having said sexual contact
with a female employee. Charles Ramsey has knowledge of the allegation against Bates. Ramsey
has not terminated Bates. Indeed, Ramey has taken no disciplinary action against Bates.
32.

William Blackurn is a minority non-white police employee and Blackburn is

under the supervision and command of Charles Ramsey; while such, Blackburn was alleged to

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have engaged in sexual misconduct towards females while on and off duty. Charles Ramsey did
not discipline or terminate Blackburn.
33.

In 2015, the City of Philadelphia itself alleges that several fireman (around 12 to

15) employed with the City Fire Department engaged in sexual misconduct on duty with another
female firefighter, which conduct the City described as a pattern of sexual misconduct. The
City has not terminated any of the fireman.
COUNT I
42 USC 1983 - Fourteenth Amendment
Equal Protection Race/Gender Discrimination
Due Process
Plaintiff vs Ramsey and Does
34.

Plaintiff incorporates here all preceding paragraphs and as if each were repeated

verbatim.
35.

Plaintiffs protected status is white male.

36.

Charles Ramsey does not belong to the protected race class as Plaintiff.

37.

Charles Ramsey is an African American male.

38.

Charles Ramsey and the City of Philadelphia by their own invidious dislike of the

white race use their authority and City or Police Department disciplinary rules, policy, practice
or custom to treated non-minoritys such as and to include the Plaintiff more harshly, differently
and less favorably than how minority non-white employees are treated under similarly situations
as the Plaintiff.
39.

Charles Ramsey under color of state law on or about April and/or May 7, 2013

intentionally deprived Plaintiff of Plaintiffs federal secured United States Constitution

Fourteenth Amendment equal protection right to be free for different treatment because of race
or gender.

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40.

Plaintiff's unequal treatment by Defendant Ramsey and the Does, is motivated

because of Plaintiff's gender or race, and/or by Ramsey and the Does animus for Plaintiff's
gender or race, which animus includes but is not limited to a goal of denying employment and/or
to subject non-minorities to a different more hash employment disciplinary rules and/or
condition for what is acceptable on or off duty conduct.
41.

As a result of Ramseys the Citys and Does acts, action or omissions, which are

stated in the paragraphs above, the Plaintiff sustained economic damages, such economic
damages as lost wages and the value of the benefits attendant to the employment, which damages
is in excess of one million dollars.
42.

Plaintiffs property gifted to him, such as his dog, was taken by the Does, Ramsey

and the City without valid or adequate due process notice and hearing being afforded pre or post
taking of the property.
43.

As a result of Ramseys the Citys and Does acts, action or omissions, which are

stated in the paragraphs above, the Plaintiff suffered personal injuries, such as emotional
anguish, loss of society and the enjoyment of life, which injuries are from the different treatment
by Ramsey and the Does. Plaintiff injuries include but are not limited to sleep, weight and mood
changes, loss of hair, upset stomach, frequent headaches, embarrassment, humiliation, and
extreme emotional distress that manifested into the aforementioned physical conditions, which
distress and injuries is from the Defendants conduct, which conduct is beyond that conduct
society is willing to accept.
44.

The direct result and/or the proximate or legal cause of Plaintiff damages and/or

injuries is defendant Ramseys and the Does unequal treatment and/or invidious dislike for

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Plaintiff and Plaintiffs race and/or gender, and the deprivation under color of state law of
Plaintiffs federally secure rights.
45.

The direct result of the deprivation of equal rights by Ramsey and/or the Does or

their invidious dislike for Plaintiff and Plaintiffs race and/or gender is the proximate or legal
cause of Plaintiff damages and/or injuries.
46.

Defendant Ramseys and the Does deprived the Plaintiff federally secure rights

to equal protection under the law and they deprived the Plaintiff of federal protected rights,
immunities, and privileges under color of state law.
COUNT II
42 USC Section 1983 Fourteenth Amendment- Monell
Policy, Practice, Custom to Treat Unequally because of Race / Gender
Failure To Supervisor Or Adequately Train
Plaintiff v. City Of Philadelphia
47.

Plaintiff repeats here all preceding paragraphs and as if each was repeated

verbatim.
48.

The City of Philadelphia through Mayor Michael Nutter hired Ramsey as Police

Commissioner.
49.

At the time the City hired Ramsey, Ramsey already had deprived persons of

constitutional rights by ordering the arrest of hundreds of persons that were engaged in lawful
free speech activity in Pershing Part, Washington D.C.
50.

The City of Philadelphia, Charles Nutter, Everett Gillison and others review

disciplinary action, such as a termination, which is imposed on City of Philadelphia employees.

51.

The City of Philadelphia, Charles Nutter, and Everett Gillison supervise Charles

Ramsey and Fire Commissioner.

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52.

The City, Nutter, and Gillison allowed or acquiesced to Ramseys indifferent

treatment of police employees which include the Plaintiff, and for Ramsey to treat employees
and to include the Plaintiff less favorably and more harshly (differently) then how similarly
situate minorities employees are treated.
53.

Michael Nutter is and was the Mayor, and Everett Gillison is and was Deputy

Mayor, for the times before during and after Plaintiffs termination.
54.

The City of Philadelphia, Charles Nutter, and Everett Gillison are provided notice

of employee terminations.
55.

The City of Philadelphia, Charles Nutter, and Everett Gillison had notice of or

knowledge about Plaintiffs termination when or shortly after the time when Plaintiff was
terminated by Charles Ramsey, which was on or about June 7, 2013 and notice of intent to
terminate was on or about May 7, 2013.
56.

The City of Philadelphia, Charles Nutter, Everett Gillison had at the time of

Plaintiffs termination the authority and power to stop Charles Ramey and/or Plaintiffs
termination, and/or for any City of Philadelphia employee that was to be terminated. .
57.

The City of Philadelphia, Charles Nutter, Everett Gillison had at the time of

Plaintiffs termination the authority and power to reverse, end or correct the Plaintiffs
termination, which termination is more harsh disciplinary treatment on a non-minority City of
Philadelphian employees than is imposed on a minority employee by Ramsey or the Fire
Commissioner.
58.

Plaintiff's unequal treatment is from a policy, practice of custom of the City, and

to include but not be limited to the police department.

59.

The City of Philadelphia, Ramsey, Nutter and Gillison have a past practice to

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condone and/or acquiesce to a deprivation of equal rights because of race and for race
discrimination within the Police Department and by police personnel, supervisor and to include
police commissioner Charles Ramsey.
60.

The City, Nutter, Ramsey and Gillison have done little if anything at all to end

unequal treatment because of race or gender discrimination within the police department and/or
the use of police department disciplinary system to accomplish the deprivation of constitutional
rights, such as equal protection rights. For example, three white male police officers that
opposed racism in the police department were terminated. In May 2008 a jury determined the
officers terminations were due to discrimination. The City and Nutter did not rehire the officers
after the jury verdict. Indeed, the City and Nutter refused to rehire the one of the officers that
asked to be rehired.
61.

The City, Nutter, Ramsey, and Gillison also have not taken adequate action to

stop the use of the disciplinary systems to facilitate racism and/or unequal treatment. For
example, no action was taken in and after May 14, 2008 against supervisor (William Colorulo)
and/or other police officer that were engaged in the unequal protection - race discrimination
against the three white police officer that were terminated for opposing the unequal treatment by
supervisor Colorulo against minority police officers.
62.

Mayor Nutter and Deputy Mayor Gillison are final decision-makers for the City

of Philadelphia.
63.

Ramsey, Nutter, Gillison and other Heads of City Department that reviewed

Plaintiff termination, knew or should have known from the Pershing Park matter and prior
misuse of the disciplinary system of the City Departments that it was likely Charles Ramsey
and/or the Citys disciplinary systems by various City Departments might result in a deprivation

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of constitutional equal protection rights without more training and adequate supervision, and that
without such Ramsey or the systems could facilitate further deprivation of constitutional equal
protection rights and illegal race or gender discrimination.
64.

Ramsey, Nutter, Gillison and other Heads of City Department that reviewed

Plaintiffs termination, knew or should have known the Plaintiffs termination by Ramsey was
further use the City Police Departments disciplinary systems to accomplish a deprivation of
constitutional fourteenth amendment right to equal right and was race or gender discrimination.
65.

The motivating reason for the Citys indifferent and unequal treatment by Ramsey

and the City is Plaintiff's gender or race, and/or Ramseys and the Does animus for Plaintiff's
gender or race, which animus and policy, practice or custom includes but is not limited to the
goal of subjecting non-minorities to a different more hash employment disciplinary rules and/or
what may be considered acceptable on duty conduct for employees.
66.

As a result of a failure to supervise and/or an inadequate supervisor of Charles

Ramsey, and/or the aforementioned policy, practice and custom that is demonstrated in the
preceding paragraphs, the Plaintiff sustained economic damages, such as lost wages and the
value of the benefits attendant to the employment, which damages is in excess of one million
dollars.
67.

As a result of a failure to supervise and/or an inadequate supervisor of Charles

Ramsey, and/or the aforementioned policy, practice and custom that is demonstrated in the
preceding paragraphs, the Plaintiff sustained or suffered personal injuries, such as emotional
anguish, loss of society and the enjoyment of life, which injuries are from the different treatment
by Ramsey and the Does. Plaintiff injuries include but are not limited to sleep, weight and mood
changes, loss of hair, upset stomach, frequent headaches, embarrassment, humiliation, and

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extreme emotional distress that manifested into the aforementioned physical conditions, which
distress and injuries is from the Defendants conduct, which conduct is beyond that conduct
society is willing to accept.

COUNT III
COMONWEALTH CONSTITION- ARTICLE I SECTION I
INHERENT RIGHTS - EQUAL PROTECTION
Plaintiff vs Charles Ramsey and Does
68.

Plaintiff repeats all prior paragraphs here and incorporates them as if each is

repeated verbatim.
69.

In violation of Plaintiff Article I Section I Commonwealth of Pennsylvania

constitution right to equal protection of the law, Defendants Ramsey and the Does caused
Plaintiff to suffer economic damages and personal injury.
70.

Under Commonwealth case Supreme Court case law, such as the Stander,

decision, which decision pertained to whether a challenge to a constructional provision was

justiciable in the post-enactment timeframe, the Pa Supreme Court reaffirmed that inherentrights precept recognized in earlier cases by stating. The Pennsylvania Supreme Court case law
demonstrate that [c]onstitutionally ordained rights must and will be protected by the Courts
against the will as well as against the vote of a majority of the people. . . . Ones right to life,
liberty, and property . . . and other fundamental rights may not be submitted to vote; they depend
on the outcome of no elections. A citizens constitutional rights can hardly be infringed simply
because a majority of the people choose that it be. Id. at 413, 250 A.2d at 478 (quoting W. Va.
State Bd. of Educ. v. Barnette, 319 U.S. 624, 638, 63 S. Ct. 1178, 1185-86 (1943)).

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71.

Defendant Ramsey and the Does lacks any valid authority in law or otherwise to

treat unequally the Plaintiff than how others are treated by Ramsey, for similar allegations of
sexual misconduct while on duty.
72.

Defendant Ramsey and the Does in violation of the Plaintiff constitutional right

deprived Plaintiff of his article I section 1 Pennsylvania constitutional inherent right to equal
protection under the law.
COUNT IV
Pennsylvania Constitution, Art. I, Sec. 1, 26, and 28.
Inherent Rights, Equal Protection and Reservation of Powers
No Discrimination by Political Subdivisions
Plaintiff vs City of Philadelphia
73.

The previously stated paragraphs are all incorporated here as though they were

repeated verbatim.
74.

The City of Philadelphia is a political subdivision as such term is intended and

defined under Commonwealth of Pennsylvania law.

75.

The City of Philadelphia is not exempt from but subject to the Commonwealth of

Pennsylvania article and rights to people of the Commonwealth of Pennsylvania.

76.

Article I of the state charter for the Pennsylvania Constitution provides, for the

protection of certain rights inherent to mankind and pre-existed.

77.

Section 1 of the Declaration of Rights for the Commonwealth Constitution,

entitled Inherent rights of mankind, provides that All men are born equally free and
independent, and have certain inherent and indefeasible rights, among which are those of
enjoying and defending life and liberty, of acquiring, possessing and protecting property and
reputation, and of pursuing their own happiness. PA. CONST. art. I, 1

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78.

In 2014, the City of Philadelphia, Mayor Nutter, Deputy Mayor Everett Gillison

and the Fir commissioner knew of and investigated but did not terminate employment of male
African American City of Philadelphia employees that were alleged to have engaged in on-duty
sexual conduct with a female African America firefighter.
79.

The termination of Plaintiff and the remaining describe adverse action was

accomplished using or misusing the high powers covered on the defendants which power they
possessed and used as appointed and/or elected persons, but used contrary to Plaintiffs
reservation of rights under Article Section 25 of the Pennsylvania Constitution.
80.

Plaintiffs termination was in violation of Article. 1. Section. 26 providing that

N[o] political subdivision (which the City of Philadelphia is) shall deny any person the
enjoyment of any civil right or discriminate against any person in the exercise of any civil right.
PA. CONST. art. I, 26 (reading Neither the Commonwealth nor any political subdivision
thereof shall deny to any person the enjoyment of any civil right, nor discriminate against any
person in the exercise of any civil right.).
81.

As a direct result of the defendants deprivation of the Plaintiffs Article I Section

and 26 rights, , the plaintiff sustained economic damages and personal injury; the proximate
cause for Plaintiffs economic damages and personal injury is the defendants deprivation of the
Plaintiffs Article I Section and 26 rights.
82.

Plaintiff sustained economic damages form the loss of employment and the wages

and benefits attendant to the employment.

83.

Plaintiff suffered extreme emotional distress, mental anguish, humiliation,

embarrassment, and loss of society and enjoyment of society from the Defendants deprivation of
said rights.

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PRAYER FOR RELIEF

WHEREFORE, Plaintiffs prays the Court enter judgment for him and against the
Defendants; to hold the Defendants joint and several liable;, and to award the Plaintiff relief to
make him whole, and to provide: (a) compensatory, consequential, and punitive damages, (b)
front and back pay, (c) negative tax consequence relief, (d) reasonable attorney fees, (e) litigation
costs, and all other relief, including equitable relief allowed by law or in equity that is just and
proper, including reinstatement, declaring the Defendants conduct violated the Plaintiffs
constitutional rights, and that the policy practice or custom unconstitutional, overly broad or
sweeping, and to enjoin the employers and defendants from unconstitutional conduct and may
not be used further but must end and be corrected with proper guidelines to prevent further
unequal protection violations.
Date: March 15, 2015

Respectfully submitted,
BY

/s/ ___________________
Brian M. Puricelli, Esq.
Attorneys for Plaintiff

LAW OFFICES OF BRIAN M. PURICELLI

691 Washington Crossing Rd. Newtown PA 18940
Ph (215) 504-8115

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