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Memorandum In Support of Plaintiffs Amended

Memorandum In Support of Plaintiffs Amended

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Published by URBNAnthony.com
UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

Anthony McKnight Sr. 19, 2012 Plaintiff, v.

DATE: April

FILE NO: 3:10cv1471(MRK) State of Connecticut ET. AL., Defendants,

Memorandum In Support of Plaintiffs Amended Complaint The plaintiff wishes to incorporate the violations committed by the defendants in their official capacities listed in plaintiffs federal complaint filed in 1995: 395cv00962 paragraphs 1 through 85. Wrongful Terminations based on unlawful Public Policy Violations, vi
UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

Anthony McKnight Sr. 19, 2012 Plaintiff, v.

DATE: April

FILE NO: 3:10cv1471(MRK) State of Connecticut ET. AL., Defendants,

Memorandum In Support of Plaintiffs Amended Complaint The plaintiff wishes to incorporate the violations committed by the defendants in their official capacities listed in plaintiffs federal complaint filed in 1995: 395cv00962 paragraphs 1 through 85. Wrongful Terminations based on unlawful Public Policy Violations, vi

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Published by: URBNAnthony.com on Apr 20, 2012
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UNITED STATES DISTRICT COURTDISTRICT OF CONNECTICUT
 Anthony McKnight Sr. DATE: April 19, 2012Plaintiff,v.FILE NO: 3:10cv1471(MRK)State of Connecticut ET. AL.,Defendants.
 Memorandum In Support
of Plaintiff’s Amended Complaint
 The Plaintiff wishes to incorporate the violations committed by the Defendants intheir official capacities listed in Plaintiff's federal complaint filed in 1995: 395cv00962paragraphs 1 through 85.Wrongful terminations based on unlawful public policy violations, violates Plaintiff rights accordingly. Employers may not terminate a civil public servant employee whohas refused to agree to an illegal act. The public policies implemented by the RowlandAdministration were illegal {See United States v John G Rowland and SEBAC v John G.Rowland, also see Executive Order 38, SEBAC Agreements IV, and V}
Obtaining Relief for a Wrongful Termination of State Employment
 State employees who have been wrongfully terminated are entitled to variousremedies under law. These may include: reinstatement to their former position, recoveryof lost wages, entitlement to back pay, and establishment of further measures forpreventing future violations.
Prospective Relief was decided by the courts in SEBAC/Rowland.
 
 
 Lucarelli v. State, 4 Conn. Workers’ Comp. Rev. Op. 58, 262 CRD
-4-83 (April 27,1987), no error, 16 Conn. App. 65 (1988). To secure benefit of full pay under statute claimant needs only to show injury was sustained in the performance of guard duties.
 The Plaintiff was unlawfully terminated by the Defendant State of Connecticut,while absent from work due an to inmate related, work compensable injuries. {Seetermination doc letters etc}The Plaintiff contends that the malfeasance of the Defendant State of Connecticut
 public officials violated Plaintiff’s civil, constitutional and statutory rights.
 The violations committed by the Defendant defrauded the Plaintiff of his statutoryentitlements and violated his rights not to be discriminated against.The Defendant State of Connecticut violated Plaintiff's rights to be treated equally tothat of similarly situated injured white corrections officers.
Federal Laws42 U.S.C. § 1981:
“All persons within the jurisdiction of the United States shall have
 the same right in every State and Territory to make and enforce contracts, to sue, be parties, give evidence, and to the full and equal benefit of all laws and proceedings for the security of persons and property as is enjoyed by white citizens, and shall be subject to like punishment, pains, penalties, taxes, licenses, and exactions of every kind, and to
no other.” 
 
42 U.S.C. § 1983 provides:
“Every person who under color of any statute, ordinance, regulation, custom, or usage,
 of any State or Territory or the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction
 
 
 thereof to the deprivation of any rights, privileges, or immunities secured by theConstitution and laws, shall be liable to the party injured in an action at law, Suit inequity, or other proper proceeding for redress, except that in any action brought against a judicial officer for an act or omission taken in such officer's judicia capacity, injunctive relief shall not be granted unless a declaratory decree was violated  or declaratory relief was unavailable. For the purposes of this section, any Act of Congress applicable exclusively to the District of Columbia shall be considered to be a
statute of the District of Columbia.” 
 APPLICABLE AMENDMENTS/CONNECTIUT CONSTITUION: WE DECLARESEC. 1. All men when they form a social compact, are equal in rights; and no man or setof men are entitled to exclusive public emoluments or privileges from the community.SEC. 2. All political power is inherent in the people, and all free governments arefounded on their authority, and instituted for their benefit; and they have at all times anundeniable and indefeasible right to alter their form of government in such manner asthey may think expedient.SEC. 11. The property of no person shall be taken for public use, without justcompensation thereof.SEC. 20. No person shall be denied the equal protection of the law nor be subjected tosegregation or discrimination in the exercise or enjoyment of his civil or political rightsbecause of religion, race, color, ancestry or national origin.
Conn. Gen. Stat.

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