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UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF OHIOCRYSTAL DIXON
,Civil Case No. ________________ Plaintiff,v.
UNIVERSITY OF TOLEDO
;
LLOYD
 
COMPLAINT
 
JACOBS
, individually and in his officialcapacity, President, University of Toledo; Hon. _______________ 
WILLIAM LOGIE
, individually and inhis official capacity Vice President for Human Resources and Campus Safety,University of Toledo;Defendants.Plaintiff Crystal Dixon (“Plaintiff”), by and through her undersigned counsel, brings this Complaint against the above-named Defendants, their employees, agents andsuccessors in office, and in support thereof, alleges the following:
INTRODUCTION
1.
 
This action asserts Plaintiff’s fundamental constitutional rights protected by the First and Fourteenth Amendments to the United States Constitution and 42 U.S.C.§ 1983. Defendants, by means of their acts, omissions, policy, practice, and/or custom,have punished Plaintiff’s private political speech on account of its viewpoint byterminating her government employment at the University of Toledo in violation of Plaintiff’s right to freedom of speech protected by the First Amendment. Furthermore,Defendants have in place a policy, practice, and/or custom that grants them unbridleddiscretion to subjectively determine which political speech is permitted and which
Case 3:08-cv-02806-DAK Document 1 Filed 12/01/2008 Page 1 of 12
 
2 political speech is restricted in violation of the First Amendment. Finally, Defendantshave denied Plaintiff access to a forum for her speech based on its viewpoint, therebydepriving Plaintiff of the equal protection of the law guaranteed by the FourteenthAmendment.2.
 
As a result of Defendants’ violations of Plaintiff’s fundamental rights,Plaintiff seeks declaratory and injunctive relief as well as nominal, compensatory, and punitive damages, and attorneys’ fees and costs.
JURISDICTION AND VENUE
3.
 
This action arises under the First and Fourteenth Amendments to theUnited States Constitution and 42 U.S.C. § 1983. Jurisdiction is conferred on this court pursuant to 28 U.S.C. §§ 1331 and 1343.4.
 
Plaintiff’s claims for declaratory and injunctive relief are authorized pursuant to 28 U.S.C. §§ 2201 and 2202, Rules 57 and 65 of the Federal Rules of CivilProcedure, and the general legal and equitable powers of this court.5.
 
This court is authorized to award nominal, compensatory, and punitivedamages for the past loss of Plaintiff’s constitutional rights and the harm caused byDefendants’ actions pursuant to 42 U.S.C. § 1983.6.
 
This court is authorized to award reasonable costs of litigation, includingattorneys’ fees and expenses, pursuant to 42 U.S.C. § 1988.7.
 
Venue is appropriate in the Northern District of Ohio pursuant to 28U.S.C. § 1391(b), because a substantial part of the events or omissions giving rise toPlaintiff’s claims occurred within this district.
Case 3:08-cv-02806-DAK Document 1 Filed 12/01/2008 Page 2 of 12
 
3
PLAINTIFF
8.
 
Plaintiff is and was at all relevant times herein a resident of Maumee,Ohio.9.
 
Plaintiff was at all relevant times herein employed by the University of Toledo, a government institution.
DEFENDANTS
10.
 
The University of Toledo (“University”), located in Toledo, Ohio, is a public entity established and organized under the laws of Ohio, with the authority to sueand be sued in its own name.11.
 
The University is charged with carrying out its own administrative andeducational operations and promulgates the policies, practices, and/or customs infurtherance thereof.12.
 
At all relevant times herein the University was a “person” acting under the color of state law pursuant to 42 U.S.C. § 1983.13.
 
Defendant Lloyd Jacobs, at all relevant times herein, was President of theUniversity and acting under color of state law. Defendant Jacobs is responsible for creating, adopting, and implementing University policies, practices, and/or customs,including those challenged within this Complaint. Defendant Jacobs is sued individuallyand in his official capacity.14.
 
Defendant William Logie, at all relevant times herein, was the VicePresident for Human Resources and Campus Safety at the University and acting under color of state law. Defendant Logie is responsible for creating, adopting, and
Case 3:08-cv-02806-DAK Document 1 Filed 12/01/2008 Page 3 of 12
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