IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TENNESSEE

AT CHATTANOOGA

AMANDA ROLLINS and )

JILL FRANKLIN, )
)
Plaintiffs, )
)
v. ) Case No. ________________
) JURY DEMANDED
ROBERT (“ROBBIE”) COLE, )
NATHAN HENDERSON )
DR. JAMES JONES, )
POLK COUNTY SCHOOL )
BOARD OF EDUCATION )
KELLY KIMSEY and TREVA HYATT )
)
Defendants. )

COMPLAINT

COMES the Plaintiffs, AMANDA ROLLINS and JILL FRANKLIN, by and through their

attorney, W. Tyler Weiss, and sues the Defendants ROBERT (“ROBBIE”) COLE, NATHAN

HENDERSON, DR. JAMES JONES, KELLY KIMSEY, TREVA HYATT and POLK COUNTY

BOARD OF EDUCATION, and for cause of action would show unto the Court as follows:

I. PRELIMINARY STATEMENT

1. The Defendants, Robert (“Robbie”) Cole, a duly elected member of the Polk

County Board of Education, Nathan Henderson, a school resource officer, Dr. James Jones, the

Polk County School Superintendent, Kelly Kimsey, Treva Hyatt, the Polk County School System

Finance Director, and Polk County Board of Education, individually and/or conspired, in

combination and/or concert, with each other and possibly others by spreading false and malicious

rumors in and around the school system and the Polk County and surrounding community by

accusing the Plaintiffs of stealing and embezzling money allegedly belonging to the Copper Basin

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Elementary School (“CBES”) and deprived the Plaintiffs of their teaching and administrative

positions at CBES. It was the Defendants’ illegal, conspiratorial, malicious, intentional, outrageous

and depraved actions that tarnished the personal and professional reputations of the Plaintiffs in

the community and the school system where Mrs. Rollins has been employed for the past 17 years

and Mrs. Franklin has been employed for the past four (4).

2. Further, the Defendants, individually and/or in combination or in concert, violated

Ms. Rollins and Ms. Franklin’s procedural and substantive due process right in accordance with

the United States Constitution, Amendment XIV and Tennessee Code Annotated § 49-5-501 et

seq. The Defendants, collectively and/or individually, wrongfully terminated Ms. Rollins and Ms.

Franklin and have prejudged and tainted any due process hearing such that any hearing would be

a sham and would violate their rights.

3. This is a civil rights action pursuant to 42 U.S.C. § 1983 seeking compensatory and

punitive damages against the Defendants, individually and/or collectively or in combination, for

committing acts under color of law, and depriving Ms. Rollins and Ms. Franklin of rights secured

by the Fourth and Fourteenth Amendments to the United States Constitution, as well as the state

law claims of defamation, false light and wrongful termination.

4. Venue is appropriate in this Court because the parties and the acts alleged occurred

within Polk County, Tennessee, which is within this Court’s judicial district.

II. JURISDICTION

5. Jurisdiction is founded upon 28 U.S.C. §§ 1331, 1343 and 1983. The Plaintiffs

request that this Court exercise its supplemental jurisdiction over the transactional state claims

pursuant to 28 U.S.C. § 1367.

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 III. PARTIES

6. The Plaintiff, AMANDA ROLLINS, at all times relevant is a citizen and resident

of 489 Campbell Cove Road, Turtletown, Polk County, Tennessee 37391. Amanda Rollins has

been employed by the Polk County Board of Education for 17 years and is a tenured teacher at the

Copper Basin Elementary School. At the times relevant to the allegations in this Complaint, Ms.

Rollins was a kindergarten teacher at Copper Basin Elementary School. Ms. Rollins is a member

of the Professional Educators of Tennessee, which has entered into a Memorandum of

Understanding with the Polk County Board of Education (the “MOU”).

7. The Plaintiff, JILL FRANKLIN, at all times relevant is a citizen and resident of

Tellico Plains, Monroe County, Tennessee. Jill Franklin has been employed by the Polk County

Board of Education as the tenured Principal of Copper Basin Elementary School for four (4) years.

At the times relevant to the allegations in this Complaint, Ms. Franklin was the tenured Principal

at Copper Basin Elementary School. Ms. Franklin is a member of the Professional Educators of

Tennessee, which has entered into a Memorandum of Understanding with the Polk County Board

of Education (the “MOU”).

8. The Defendant, ROBBIE COLE, at all times relevant is a citizen and resident of

Polk County, Tennessee. Defendant, Robbie Cole, is employed with the Polk County Sheriff’s

Department and is a School Resource Officer at Copper Basin High School. The Defendant,

Robbie Cole, is a duly elected member of the Polk County Board of Education as was an elected

member at all times relevant herein. Mr. Cole is being sued individually and in his official

capacities as an officer with the Polk County Sheriff’s Department and a duly elected member of

the Polk County Board of Education. Defendant, Robbie Cole, was at all times relevant acting

under color of law and under the customs and usages of the State of Tennessee. Defendant Cole

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was at all times relevant a private citizen who acted in concert and combination with Defendants

Hyatt, Jones, Kimsey, Henderson and the School Board in conspiring to and effectuating the

violation of Plaintiffs Fourteenth Amendment rights, as well as her rights secured by Tennessee

Code Annotated and other state law causes of action set out herein.

9. The Defendant, NATHAN HENDERSON, at all times relevant is a citizen and

resident of Polk County, Tennessee. Defendant, Nathan Henderson, is employed with the Polk

County Sheriff’s Department and was the School Resource Officer for the Copper Basin

Elementary School at all times relevant. Mr. Henderson is being sued individually and in his

official capacity as an officer with the Polk County Sheriff’s Department. Defendant, Nathan

Henderson, was at all times relevant acting under color of law and under the customs and usages

of the State of Tennessee. Defendant Henderson was at all times relevant a private citizen who

acted in concert and combination with Defendants Hyatt, Jones, Cole, Kimsey and the School

Board in conspiring to and effectuating the violation of Plaintiffs Fourteenth Amendment rights,

as well as her rights secured by Tennessee Code Annotated and other state law causes of action set

out herein.

10. The Defendant, KELLY KIMSEY, at all times relevant is a citizen and resident of

Polk County, Tennessee. Defendant Kimsey was at all times relevant a private citizen who acted

in concert and combination with Defendants Hyatt, Jones, Cole, Henderson and the School Board

in conspiring to and effectuating the violation of Plaintiffs Fourteenth Amendment rights, as well

as her rights secured by Tennessee Code Annotated and other state law causes of action set out

herein.

11. The Defendant, TREVA HYATT, at all times relevant is a citizen and resident of

Polk County, Tennessee. The Defendant, Treva Hyatt, is employed by the Polk County School

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system and works in the central office. Ms. Hyatt is the Polk County School System Finance

Director. Defendant Hyatt was at all times relevant a private citizen who acted in concert and

combination with Defendants Kimsey, Jones, Cole, Henderson and the School Board in conspiring

to and effectuating the violation of Plaintiffs Fourteenth Amendment rights, as well as her rights

secured by Tennessee Code Annotated and other state law causes of action set out herein.

12. The Defendant, DR. JAMES JONES, at all times relevant is a citizen and resident

of Polk County, Tennessee. Defendant, Dr. James Jones is the Director of Schools for the Polk

County School System. Dr. Jones is being sued in his individual capacity and his official capacity

as the Director of Schools for the Polk County School System. Defendant, Dr. James Jones, was

at all times relevant acting under color of law and under the customs and usages of the State of

Tennessee. Defendant Jones was at all times relevant acted in concert and combination with

Defendants Hyatt, Kimsey, Cole, Henderson and the School Board in conspiring to and

effectuating the violation of Plaintiffs Fourteenth Amendment rights, as well as her rights secured

by Tennessee Code Annotated and other state law causes of action set out herein.

13. The Defendant, POLK COUNTY BOARD OF EDUCATION, (the “School

Board”) is a political subdivision of the State of Tennessee and responsible for providing education

to the children within its jurisdiction and for administering the laws and policies that govern the

public schools within its jurisdiction, which includes the Polk County School System. Its principal

address is 131 Stephens Street, Benton, Tennessee 37307. Its registered agent is Dr. James Jones,

the Director of the Polk County School District, and the registered agent’s address is 131 Stephens

Street, Benton, Tennessee 37307.

IV. STATEMENT OF FACTS

14. Plaintiffs incorporate by way of reference the preceding paragraphs of this

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Complaint as if fully set forth herein.

15. In September 2018, the School Board approved for Copper Basin Elementary

School (the “CBES”) to take the students on a field trip to Nashville, Tennessee and to Savannah,

Georgia. During the 2018-2019 school year, the parents of the children had several fundraising

events such as, Fried Green Tomato Festival, Dances, Bake Sales, Raffles, and Cougar Cards to

raise money for the field trip.

16. In the previous year, CBES took a field trip to Washington D.C. and money was

raised by the students’ parents in the similar manner, including a donation matching program. The

School Board gave its approval and Defendants Jones, Cole and the School Board had knowledge

of how the parents were raising money for their children to go on that field trip.

17. On or about April 20, 2019, Defendant Jones received a call from Defendant Cole

about an incident he needed to discuss with him in person. Upon information and belief, Defendant

Jones met with Defendants Cole and Henderson and discussed the CBES field trip fundraising,

including a Whirlpool donation matching program. Upon information and belief, Defendants Cole,

Jones and Henderson discussed among themselves the field trip fund raising activities and accused

Ms. Rollins and Ms. Franklin of embezzlement, stealing money and fraud.

18. Upon information and belief, the Defendants, collectively and individually, had

received a complaint or complaints from parents of students at CBES about the parents fundraising

activities and their child being upset because he/she did not have money to purchase a snack or

other item.

19. On or about April 20, 2019, Defendant Jones demanded to immediately meet with

Ms. Rollins, Ms. Franklin and Melissa Lance at CBES. Ms. Rollins was in the middle of

administering a TCAP test to some students, which is considered a major disturbance or

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inconsistency of the TCAP test. Ms. Lance was a bookkeeper at CBES and was responsible for

properly recording and accounting for any funds received at CBES. The only people in this meeting

was Defendant Jones and Ms. Rollins, Ms. Franklin and Ms. Lance.

20. At that meeting, Defendant Jones immediately suspended, without pay, Ms.

Franklin and Ms. Rollins. Defendant Jones told Ms. Rollins and Ms. Franklin they have committed

a criminal offense and they would probably be arrested, charged with theft and go to prison.

Defendant Jones also immediately fired Ms. Lance. Upon information and belief, Melissa Lance’s

job was filled by a School Board member’s wife soon after.

21. The day after Ms. Franklin was suspended, Defendant Cole told Beth Dlugokinski,

who became the interim principal at CBES, that Amanda Rollins must be embezzling money from

CBES because she would not be driving a Lexis and living in a house on the lake otherwise.

22. Also, on or about April 25, 2019, Defendant Cole told the sheriff that Ms. Rollins

and Ms. Franklin were stealing money and wanted the sheriff to take action against them. In late

May, Defendant Cole said to Lavonne Collins that the Rollins/Franklin matter was another “Mark

Stone case” and they were stealing money. Mark Stone was a former football/softball coach at

Copper Basin High School who misused and misappropriated equipment and funds. From the

investigation into Coach Stone, money was determined to be missing and unaccounted for.

23. Students at CBES have told Ms. Rollins daughter that she was arrested because she

was stealing from CBES and giving the money to kids at other schools. Ms. Franklin’s nieces and

nephews were also told that Ms. Franklin was escorted out of the CBES building in handcuffs and

criminally charged. Several other students have said that Ms. Rollins and Ms. Franklin were fired

for stealing money.

24. In fact, Defendant Henderson’s daughter is one of the primary instigators and told

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Ms. Rollins daughter that her dad arrested Ms. Rollins and took her to jail for stealing money.

Other citizens in the community have told Ms. Rollins that it is being told that Defendant

Henderson arrested Ms. Rollins for theft. Clearly these children, especially Defendant Henderson’s

daughter, are hearing the slanderous statements from their parents, relatives, friends and others

throughout the community.

25. On or about May 10, 2019, Ms. Rollins was told to leave the school property while

she was watching her son’s football scrimmage game from administration. Ms. Rollins was afraid

that she would be escorted off the property by the police if she did not immediately leave. Ms.

Rollins missed her son’s football scrimmage game and was humiliated.

26. On or about July 12, 2019, it was learned that Janees Nipper was the new

elementary principal and that Ms. Rollins kindergarten position was on job postings and that Ms.

Rollins and Ms. Franklin were being replaced. In fact, Ms. Nipper, the new CBES principal who

replaced Ms. Franklin, is the close friend of Defendant Hyatt’s daughter.

27. On or about July 16, 2019, Mrs. Nipper sent Amanda Rollins a message asking her

when she could get her things out of the class and told her that she had been fired.

28. On or about July 18, 2019, Dr. James Jones sent Amanda Rollins a message on

phone stating, “as you have been told by the principal, you will not be working for us in the

upcoming school year. I will be sending you a certified letter stating such tomorrow. . . .” However,

Ms. Rollins has never received a certified letter.

29. On or about August 3, 2018, the Polk County School System Internal School Funds

Annual Financial Report for the year ended June 30, 2018 (the “2018 Audit”) was released. From

the 2018 Audit, Defendant Jones and the School Board were under a Corrective Action Plan, which

was a result of improper fundraising collection and booking actions. According to the Corrective

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Action Plan “two schools did not properly follow cash collection procedures for fundraisers . . . .”

30. Upon information and belief, the two (2) schools were Benton Elementary and

Chilhowee Middle School. The Corrective Action Plan further stated that “[t]he fundraiser

collection procedure errors have been specifically addressed with the principals and bookkeepers

at the two schools with the findings.” See 2018 Audit.

31. Upon information and belief, the principals, teachers or bookkeepers at the two (2)

schools who were not following the proper fundraiser collections procedure were not suspended,

without pay, or terminated and did not get accused of theft, fraud or money laundering.

32. In fact, only the “Internal school fund bookkeepers [were] required to attend

training on procedures required for collection of money and fundraiser documentation.” Upon

information and belief, the principals nor the teachers had any required training obligations and

the 2018 Audit merely states that the “fundraiser collection procedure errors have been specifically

addressed with the principals . . . .” See 2018 Audit.

33. On or about June 18, 2019, Defendant Jones addressed the school board concerning

the status of Ms. Rollins and Ms. Franklin. Defendant Jones stated that it is very unlikely that arrest

warrants would be issued against Ms. Rollins and Ms. Franklin. However, the Defendants Jones,

Cole, Henderson and the School Board continued to assert and represent to the public that Ms.

Rollins and Ms. Franklin had committed fraud, theft and/or money laundering because they had

not followed the proper due process and statutory procedures afforded to teachers.

34. It is clear that Defendant Jones, who has actually said it, and the School Board never

had the intentions of allowing Ms. Rollins or Ms. Franklin to continue their employment with Polk

County School System. In fact, the actions of the Defendants Jones, Cole and School Board

indicate that they have prejudged this issue and have effectively fired Ms. Rollins and Ms. Franklin

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 and have not gave them due process of law or afforded them the statutory processes under the

Tennessee Code Annotated or the Memorandum of Understanding entered into between the School

Board and Professional Employees of Polk County (the “MOU”).

35. Upon information and belief, Defendant Hyatt, among others, does not like Ms.

Franklin because Ms. Franklin fired Defendant Kimsey for falsifying her timecard. It was no secret

that Defendant Kimsey did not like Ms. Franklin, in fact hated her, after Defendant Kimsey was

fired, and she believed Ms. Franklin was evil and was looking for ways to “expose her” and get

vengeance. Defendant Kimsey and Defendant Hyatt are close friends and Defendant Hyatt and

Defendant Kimsey have been looking for opportunities to get Ms. Franklin back and get

vengeance.

36. In July 2019, someone contacted Whirlpool and accused Tony Rollins, Ms. Rollins

husband, of fraud and other criminal acts associated with the donation matching program. Tony

Rollins works for Whirlpool and has for several years. Upon information and belief, the caller was

acting on behalf of and/or with the encouragement of the Defendants.

37. On or about July 30, 2019, Tony Rollins was questioned by a Whirlpool lawyer

about the person’s allegation that made in the phone call and accusing Mr. and Ms. Rollins and

Ms. Franklin of money laundering and being involved in a kick-back scheme.

38. To this date, Ms. Rollins and Ms. Franklin have not received any due process

hearing or been afforded any rights as tenured teachers nor have they been afforded any right to

defend their actions or their reputation.

39. The Defendants have purposefully classified any audit and investigation into the

field trip fundraising accounting issue as criminal to effectively deprive Ms. Rollins and Ms.

Franklin of their procedural and substantive due process rights. Defendant Cole has repeatedly

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 asserted that Ms. Rollins and Ms. Franklin will be prosecuted for theft.

40. Defendants Jones, Cole, Hyatt and the School Board know that the Tennessee Code

Annotated, Polk County Board of Education policies and procedures and the MOU would require

due process hearings and a completion of any investigation within 90 days of the suspension when

there is no criminal investigation. Defendant Jones specifically told the School Board that it is not

expected that criminal warrants would be issued against Ms. Rollins and Ms. Franklin on or about

June 18, 2019.

41. It has been almost six (6) months since Ms. Rollins and Ms. Franklin have been

initially suspended and approximately three (3) months since Defendant Jones made his assertion

to the School Board that no criminal warrants were likely to be forthcoming.

42. Ms. Rollins and Ms. Franklin have made demands to Defendants Jones and the

School Board to have their due process hearing and attempt to clear their name.

43. Upon information and belief, Defendant Jones, Cole, Hyatt and the School Board

did not reprimand, suspend, terminate or take any negative employment action against the

principals or teachers of the other schools within the school system for accounting irregularities

pursuant to the 2018 Audit.

44. As a result of the Defendants actions, individually and/or collectively and in

combination, Ms. Rollins and Ms. Franklin has suffered damages, financially, emotionally,

physically and to their reputation.

45. The Defendants, acting solely and/or in concert and in combination, was reckless,

malicious, willful, intentional, oppressive and taken with a motive to intentionally harm Ms.

Rollins and Ms. Franklin and/or violate their clearly established constitutional rights and

Tennessee statutory and common law rights and/or with such reckless disregard of those clearly

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 established rights so as to render these Defendants liable to Ms. Rollins and Ms. Franklin for

punitive damages.

V. CAUSES OF ACTION
Count A – Tennessee Defamation/False Light/Conspiracy to Defame

46. Plaintiffs incorporate by way of reference the preceding paragraphs of this

Complaint as if fully set forth herein.

47. As described above, the Defendants, individually and/or in concert or in

combination, made and published vicious, patently false and misleading facts about Ms. Rollins

and Ms. Franklin. The Defendants acted intentionally to spread the defamatory statements, or in

the alternative, they acted with reckless disregard of the truth in derogation of the common law of

the State of Tennessee.

48. As described above, the Defendants’ actions have painted Ms. Rollins and Ms.

Franklin in a false light before the public. The Defendants were negligent and/or reckless in failing

to ascertain the truth or falsity of the allegations and statements that they published and made

throughout the community. Alternatively, the Defendants acted with actual malice and/or

recklessly in publishing and making the statements.

49. As a result of the Defendants defamatory, slanderous, and libelous actions and

statements, which were done, individually and/or collectively and in combination, Ms. Rollins and

Ms. Franklin have suffered injury to their reputation in the community.

50. The Defendants’ conduct, individually and/or collectively or in combination,

harmed and caused damage to Ms. Rollins and Ms. Franklin physically, emotionally, financially

and to their reputation.

Count B – Improper Discharge/Conspiracy to Discharge

51. Plaintiffs incorporate by way of reference the preceding paragraphs of this

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 Complaint as if fully set forth herein.

52. As described above, the Defendants’ conduct, individually and/or collectively and

in combination, constituted a breach of Ms. Rollins and Ms. Franklins actual and/or implied

teaching contract.

53. The Defendants’ actions were taken individually and/or in concert and in

combination, was reckless, malicious, willful, intentional, oppressive and taken with a motive to

intentionally harm Ms. Rollins and Ms. Franklin and/or with such reckless disregard of those

clearly established rights and protections so as to render these Defendants liable to Ms. Rollins

and Ms. Franklin for punitive damages.

54. The Defendants’ conduct, individually and/or collectively or in combination,

harmed and caused damage to Ms. Rollins and Ms. Franklin physically, emotionally, financially

and to their reputation.

Count C – Violation of 42 U.S.C. § 1983/Deprivation of Procedural & Substantive Due

Process/Conspiracy to Violate 42 U.S.C. § 1983

55. Plaintiffs incorporate by way of reference the preceding paragraphs of this

Complaint as if fully set forth herein.

56. As described above, Defendants, individually and/or in concert and/or in

combination, deprived Ms. Rollins and Ms. Franklin of their rights to procedural and substantive

due process secured by the Polk County Board of Education Policies and Procedures, the MOU,

Tennessee Code Annotated § 49-5-501 et seq. and the Fourteenth Amendment to the United States

Constitution, respectively, while acting under color of state law, in violation of § 1983 and the

Fourteenth Amendment.

57. The Defendants’ conduct, individually, collectively and/or in combination, was

undertaken with malice or reckless disregard for or with indifference to Ms. Rollins and Ms.

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 Franklin’s federally protected rights.

58. The Defendants’ actions were taken individually and/or in concert and in

combination, was reckless, malicious, willful, intentional, oppressive and taken with a motive to

intentionally harm Ms. Rollins and Ms. Franklin and/or violate their clearly established

constitutional rights and/or with such reckless disregard of those clearly established rights so as to

render these Defendants liable to Ms. Rollins and Ms. Franklin for punitive damages.

59. The Defendants’ conduct, individually and/or collectively or in combination,

harmed and caused damage to Ms. Rollins and Ms. Franklin physically, emotionally, financially

and to their reputation.

VI. PRAYER FOR RELIEF

WHEREFORE, premises considered, the Plaintiffs, AMANDA ROLLINS and JILL

FRANKLIN, would respectfully requests from this Court the following relief:

1. That the Plaintiff, JILL FRANKLIN, be reinstated to her tenured principal position

at Copper Basin Elementary School and grant her a permanent injunction enjoining Defendants,

their officers, successors, assigns, and all persons acting in concert with them from further

violating § 1983, the U.S. Constitution Amendment XIV, Tenn. Code Ann. § 49-5-501 et seq. and

Tennessee law;

2. That the Plaintiff, AMANDA ROLLINS, be reinstated to her tenured teaching

position at Copper Basin Elementary School and grant her a permanent injunction enjoining

Defendants, their officers, successors, assigns, and all persons acting in concert with them from

further violating § 1983, the U.S. Constitution Amendment XIV, Tenn. Code Ann. § 49-5-501 et

seq. and Tennessee law;

3. That this Court enter a judgment for the Plaintiffs awarding them compensatory

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 and/or punitive damages;

4. That the Defendants, individually and/or collectively, are ordered to make the

Plaintiffs whole and award them all legal and equitable relief available for the unlawful conduct

described in their Complaint, including: (a) back pay and damages for lost benefits; (b)

reinstatement with restoration of all benefits and seniority or alternatively, front pay and damages

for lost benefits; (c) compensatory damages for embarrassment, humiliation, emotional distress

and anxiety, inconvenience, damage to reputation and loss of enjoyment of life; (d) punitive

damages against the individual defendants under 42 U.S.C. § 1983 and Tennessee common law;

(e) attorney’s fees, costs and litigation expenses; and (f) prejudgment interest and, if applicable,

post-judgment interest;

5. The Plaintiffs demand a trial by jury of all issues triable of right by a jury;

6. That the Court exercise its supplemental jurisdiction pursuant to 28 U.S.C. § 1367

over the Plaintiffs’ transactional state claims;

7. That this Court award the Plaintiffs their reasonable attorney’s fees and costs

pursuant to 42 U.S.C. § 1988;

8. That they be awarded such other and further legal or equitable relief to which they

may be entitled.

Respectfully submitted this 5th day of October 2019.

WORTHINGTON & WEISS, P.C.

s/W. Tyler Weiss

W. Tyler Weiss [BPR No. 028801]
409 N. College Street, Suite 1
Madisonville, Tennessee 37354
Office: (423) 442.5353
Fax: (423) 442.3866
Email: tweiss@worthingtonweiss.com
Counsel for Amanda Rollins and Jill Franklin

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