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Todd Crawley lawsuit

Todd Crawley lawsuit

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Published by Barbara Miller
Todd Crawley lawsuit
Todd Crawley lawsuit

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Published by: Barbara Miller on Jun 25, 2013
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07/10/2013

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IN THE UNITED STATES DISTRICT COURTFOR THE MIDDLE DISTRICT OF PENNSYLVANIA
TODD A. CRAWLEY,:No.Plaintiff::vs:Civil Action
 – 
Law:(Electronically filed)HARRISBURG AREA:COMMUNITY COLLEGE; JOHN:J. SYGIELSKI in his individual and:Jury Trial Demandedofficial capacity; And DENNIS P.:HEINLE, in his individual and official:capacity,:Defendants:
COMPLAINT
NOW COMES Plaintiff, Todd A. Crawley, by and through his counsel, Clark & Krevsky, LLC, who files the following Complaint:
INTRODUCTION
1.This action is initiated by Mr. Crawley, a current employee of Harrisburg
Area Community College (“HACC”), who alerted officials of said college of its
material violations of law and who, after alerting these officials of the materialviolations, experienced retaliation and discrimination. Mr. Crawley seeks relief under the False Claims Act, 31 U.S.C. §§3729-
3733 (the “False Claims Act”) andPennsylvania’s Whistleblower Law, Act of December 12, 1986, P.L. 1559 (the
Case 1:13-cv-01717-CCC Document 1 Filed 06/24/13 Page 1 of 26
 
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“Whistleblower Law”), 43 P.S. §1421
et seq
., against HACC; its president, John J.
Sygielski (“Sygielski”); and its interim chief human resources officer, Dennis P.Heinle (“Heinle”).
PARTIES, JURISDICTION & VENUE
2.Mr. Crawley is an adult individual and citizen of the Commonwealth of Pennsylvania having a principal residence at 314 E. King Street, Shippensburg, PA17257.3.
Defendant HACC is a “community college” established and operated under 
authority of Article XIX-A of the Public School Code of 1949, Act of March 10,1949, P.L. 30, 24 P.S. §§1901-A
 — 
1918-A; HACC operates campuses in thecounties of Dauphin, Adams, Lancaster, Lebanon and York, and has its principalplace of business located at 1 HACC Drive, Harrisburg, PA 17110.4.Defendant Sygielski is an adult individual and citizen of the Commonwealthof Pennsylvania having a principal place of business at 1 HACC Drive, Harrisburg,PA 17110. At times relevant hereto, Defendant Sygielski was the President of HACC. Defendant Sygielski is sued in his individual andofficial capacities.5.Defendant Heinle is an adult individual and citizen of the Commonwealth of Pennsylvania having a principal place of business at 1 HACC Drive, Harrisburg,
PA 17110. At times relevant hereto, Defendant Heinle was Defendant HACC’s
Case 1:13-cv-01717-CCC Document 1 Filed 06/24/13 Page 2 of 26
 
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Interim Chief Human Resources Officer. Defendant Heinle is sued in his individualand official capacities.6.This Court has jurisdiction pursuant to 28 U.S.C. §1331 as the case arisesunder the False Claims Act; this Court also has supplemental jurisdiction over stateclaims under 28 U.S.C. §1367.7.Venue lies within the Middle District of Pennsylvania pursuant to 28 U.S.C.§1391(d) as the facts and circumstances, acts and/or omissions, and incidents and/oractions alleged herein took place in this judicial district.
BACKGROUND FACTS
Plaintiff’s Employment History with HACC
8.Prior to April 2006, Mr. Crawley served as the Facility Safety Manager of Case Western Reserve University in Cleveland, OH.9.In April of 2006, HACC hired Mr. Crawley as Safety Coordinator; in saidposition:a.Mr. Crawley was responsible for developing, maintaining, andmanaging safety affairs for the college;b.
Mr. Crawley reported to HACC’s Director of Safety and Security.
10.In 2009, HACC promoted Mr. Crawley to the position of Director oEnvironmental Health and Safety; in said position:
Case 1:13-cv-01717-CCC Document 1 Filed 06/24/13 Page 3 of 26

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