Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Look up keyword
Like this
3Activity
0 of .
Results for:
No results containing your search query
P. 1
Craig Player v Dallas County

Craig Player v Dallas County

Ratings: (0)|Views: 3,351 |Likes:
Published by Robert Wilonsky

More info:

Published by: Robert Wilonsky on Oct 02, 2012
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

11/30/2012

pdf

text

original

 
UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF TEXASDALLAS DIVISIONCRAIG S. PLAYER §§Plaintiff, §§v. § CIVIL ACTION NO.§DALLAS COUNTY, TEXAS § JURY REQUESTED§Defendant. §PLAYER
CRAIG S. PLAYER’S
ORIGINAL COMPLAINTJURISDICTION AND VENUE
 1.
 
This case alleges a violation of procedural due process under theFourteenth Amendment, which is codified under 42 U.S.C. § 1983. Further, theCivil Rights Attorney Fees Act, as amended, is application to this case under 42U.S.C. § 1988.
 
2.
 
This case also alleges violation of the Fair Labor Standard Act
(“FLSA”). 29 U.S.C. § 206, 207.
 
3.
 
Additionally, this case alleges a state claim under pendent orsupplemental jurisdiction for violation of T
EX
.
 
G
OV
T
C
ODE
§ 617.005.
 
4.
 
Jurisdiction for this Court is invoked under 28 U.S.C. § 1343.
 
Case 3:12-cv-03947-N Document 1 Filed 10/01/12 Page 1 of 14 PageID 1
 
C.S. Player’s Original Complaint – 
Page 2
5.
 
The acts or omissions which serve as the basis for this cause of actionoccurred in Dallas, Dallas County, Texas, and venue is proper in this Court under29 U.S.C. § 1391(b).
PARTIES
 6.
 
Player
Craig S. Player (“Player”) is a former deputy
constable of the
Dallas County Constable’s Office. He is a residence of Dallas County, Texas.
 
7.
 
Dallas County
Dallas County, Texas (“Dallas County”) is a county
government with the right to sue and be sued. Dallas County may be servedprocess by serving Dallas County Judge Clay Jenkins, 411 Elm Street, Dallas,Texas 75202.
 
FACTSBackground
 8.
 
Craig S. Player is a licensed peace officer in the State of Texas, withover twenty-seven (27) years of experience in law enforcement, corrections, andacademic campus security.9.
 
Player is a former employee, particularly a deputy constable, with the
Dallas County Constable’s Office, Precinct 1 (“Precinct 1”).
The Constable inPrecinct 1
during Player’s career was Derick Evans (“Evans”).
 
10.
 
Player was hired on or around August 9, 2005 by Precinct 1 in thecivil division, particularly executing service of process.
 
Case 3:12-cv-03947-N Document 1 Filed 10/01/12 Page 2 of 14 PageID 2
 
C.S. Player’s Original Complaint – 
Page 3
11.
 
During the cours
e of Player’s employment,
he was transferred to thewarrant division, traffic division, and the more-favorable Warrant Strike Force,which consisted of the best deputy constables from each of the Dallas Countyprecincts for the purpose of capturing the individuals with the highest fines.
 
12.
 
Evans required Player and other deputy constables in the precinct toparticipate in his campaign as a condition of employment, including passing outflyers and selling $250.00 worth of raffle tickets each year. The campaigningoccurred while Player was on duty and off duty.
 
13.
 
Player was required to give various amounts of money to Evans as acondition of employment and for approval of off-duty employment. Playerestimates that he contributed approximately $100 per year to va
rious “funds” at
Precinct 1, including the coffee fund and the telephone fund.
 
14.
 
Player was also required to participate in Evans’ towing scandal, in
which Dowdy Ferry was required to tow all cars for Precinct 1, in exchange forEvans receiving approximately $35 kick back. Player was not aware of thisscandal at the time, and he did not receive money from having cars towed byDowdy Ferry.
 
15.
 
Player was terminated from the Dallas County Constable’s Office on
June 3, 2011.
 
Case 3:12-cv-03947-N Document 1 Filed 10/01/12 Page 3 of 14 PageID 3

You're Reading a Free Preview

Download
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->