Wallace 2019

Case 3:19-cv-00391-MPS Document 1 Filed 03/14/19 Page 1 of 38
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
PEKAH WALLACE : CASE NO.:

Plaintiff :
:
V. :
:
CHERYL SHARP, in her official and :
individual capacities, TANYA HUGHES, :
in her official and individual capacities, :
and CONNECTICUT COMMISSION ON :
HUMAN RIGHTS AND OPPORTUNITIES :
Defendants : MARCH 14, 2019
COMPLAINT
I. INTRODUCTION
1. This is a civil action for damages and equitable relief against Cheryl Sharp
and Tanya Hughes in their official and individual capacities, and the
Connecticut Commission on Human Rights and Opportunities, for violation of
Connecticut General Statutes Section 31-51q; retaliation against Plaintiff
because of her constitutionally protected speech in violation of the First
Amendment to the United States Constitution, as enforced through 42 U.S.C.
Section 1983; violation of Plaintiff’s right to equal protection under the law as
guaranteed by the Fourteenth Amendment to the United States Constitution
and as enforced through 42 U.S.C. Section 1983; intentional infliction of
emotional distress; tortious interference with contractual relations; and
defamation.
II. PARTIES
2. Plaintiff, Pekah Wallace (“Wallace”), is an individual residing in the State of
Connecticut. At all times relevant to this Complaint, Wallace was employed
by the Defendant Connecticut Commission on Human Rights and
Opportunities as Regional Manager of the Capitol Region.
3. Defendant, Cheryl Sharp (“Sharp”), is an individual residing in the State of
Connecticut. At all times relevant to this Complaint, Sharp was employed by
the Defendant Connecticut Commission on Human Rights and Opportunities
as Deputy Executive Director and acted under color of state law in that
capacity.
4. Defendant, Tanya Hughes (“Hughes”), is an individual residing in the State of
Connecticut. At all times relevant to this Complaint, Hughes was employed
by the Defendant Connecticut Commission on Human Rights and
Opportunities as Executive Director and acted under color of state law in that
capacity.
5. Defendant, Connecticut Commission on Human Rights and Opportunities
(“CHRO”) is an agency and instrumentality of the State of Connecticut, duly
organized and existing under the laws of the State of Connecticut. At all
times relevant to this Complaint, CHRO was Wallace’s employer.
III. JURISDICTION AND VENUE
6. This Court has subject matter jurisdiction over this matter pursuant to 28
U.S.C. Section 1331 because it asserts federal questions under 42 U.S.C.
Section 1983, the First Amendment to the United States Constitution, and the
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Fourteenth Amendment to the United States Constitution, and because
claims under Connecticut General Statutes Section 31-51q also present a
federal question.
7. This Court has subject matter jurisdiction over Wallace’s state law claims
pursuant to 28 U.S.C. Section 1332.
8. Venue is proper in the District, as each of the actions giving rise to this lawsuit
occurred within this District.
IV. FACTS
A. Wallace’s Exemplary Service to CHRO and the Public
9. Wallace was employed by CHRO for over 21 years in a variety of professional
capacities. She served as manager of the Waterbury Regional Office for 11
years and in 2013, was appointed manager of the Capital Region Office.
Throughout her career, Wallace performed at the highest professional level as
measured by the volume and timeliness of case closings, amounts of
recoveries for complainants, increasing staff efficiency, assisting the public,
and creating a positive image of the Commission in the community. Wallace
has been a leader in the use of effective mediation techniques to resolve
cases efficiently and appropriately.
10. Wallace’s initial 6 years with the Commission from 1985-1990 as an
investigator were very successful. The late Arthur Green, the Commission's
most widely celebrated Executive Director, relied on Wallace to assume
investigation of some of the most difficult, complex, and politically sensitive
cases to minimize exposure and expedite proper resolution of those cases.
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11. In March 2002, then-Executive Director Cynthia Watts Elder invited Wallace to
return to the Commission to manage the West Central Regional Office
(Waterbury Office) with an emphasis on mediating more cases and
eliminating the Region’s aged inventory. Within 18 months of her arrival,
Wallace brought the case inventory of over 600 cases under statutory time
frames and obtained over $3 million in monetary recoveries for Complainants.
Wallace’s staff referred to her as the “working manager” and to Cynthia Watts
Elder, Wallace was her “star manager.” As manager of the Waterbury Office,
Wallace maintained a standard of timely case closures and monetary
recoveries for complainants unrivaled by any of the other regional offices.
12. In June 2010, Wallace was named Humanitarian of the Year by The NAACP
Greater Waterbury Branch and received citations from the President Pro
Tempore of the Connecticut General Assembly and Speaker of the House of
Representatives. Wallace also received accolades from various governmental
and community organizations, other members of the General Assembly and
attorneys of both complainants’ and respondents’ Bars.
13. At the CHRO’s monthly meeting in July 2010, Wallace was recognized by the
CHRO Commissioners and the Agency’s Executive Director for her consistent
and successful leadership in the enforcement of civil rights laws and the
promotion of equal rights and opportunities for all people.
14. In 2011, the NAACP State Conference again recognized Wallace among its
100 Most Distinguished Black professionals in the State of Connecticut.
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15. On November 1, 2013, Wallace transferred from the Waterbury Office to
manage the Capitol Region Office in Hartford. Hughes was new to her
position as interim Executive Director and Wallace recalls asking Hughes if
she would like to be the first Executive Director to have a zero-aged case
inventory in all four Regions. Wallace promised her full support to Hughes.
16. Wallace created a structure in which investigators would experience greater
success and at the same time feel a greater sense of satisfaction and well-
being. Productivity doubled and in one instance nearly tripled. By the end of
the enforcement year, July 1, 2013 to June 30, 2014, Capitol Region reduced
the aged case inventory from 52 cases (aged 24 months or more) to 12 cases
(aged 24 months or more) and investigated and resolved 500 cases, a record
closure for the Capital Region. During the same period the Waterbury Office
closed 346 cases, the Bridgeport Office closed 219 cases and the Norwich
Office closed 322 cases.
17. In Fiscal Year 2014/2015, Wallace’s staff investigated and resolved 539
cases, again the highest closure rate among the Regions. During this same
period, one investigator retired, another investigator took FMLA leave for 6
months and a third investigator was in the process of retiring. These case
closure results were due in large measure to Wallace’s hard work and
effective management of her Region.
18. While the change in management was initially met with some resistance,
investigators for most part were stunned by the level of success they
achieved within such a short time of Wallace’s arrival. Wallace has won the
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affection and respect of her staff and is very much liked and respected by the
public. Ms. Wallace cares deeply for the work she does and the people who
have come to rely on her as a credible, caring, and trustworthy voice for over
34 years combined within CHRO and the larger civil rights community. Pro se
Complainants and small business owners unable to afford proper legal
representation, and the legal community, have come to rely heavily on
Wallace’s expertise and willingness to make herself available on short notice
(even if it means working long hours into the evenings), to expedite special
cases, cut costs, and save time and resources often consumed by a lengthy
CHRO process. Wallace believes that when she and her staff perform well the
public is well served, public perception of CHRO is enhanced, and the
Administration benefits greatly.
19. Wallace consistently was the top performing Regional Manager in the CHRO,
providing outstanding service to the public. Her Region consistently
processed more cases to conclusion than the other Regional Offices. This
means that significantly more citizens have achieved results from their
complaints in Wallace’s Region because of her efforts. Her service to the
public has been repeatedly recognized by the Legislature and leading
minority groups.
20. Despite her proven track record of achieving positive results for the
Commission and the public it serves, Wallace was unable to perform at her
fullest potential because of unrelenting retaliation and harassment being
perpetrated against her by Sharp and Hughes.
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B. Wallace’s Protected Speech
21. The retaliation against Wallace began when Wallace objected to Hughes and
Sharp disseminating inaccurate case closure reports both internally and
externally.
22. By the end of Fiscal Year 2013/2014, Capitol Region had successfully closed
approximately 593 cases, 102 of which were cases transferred to the Capital
Region from other Regions. The 102 transferred cases were reviewed,
evaluated, processed, and closed by Capitol Region staff under the
supervision of Wallace.
23. At the time, the CHRO’s Case Tracking System (“CTS”) was unable to
properly attribute cases that were transferred to the Capitol Region from other
regions.
24. Sharp and Hughes, prepared, disseminated and/or relied upon inaccurate
case closure reports that effectively reduced the Capital Region’s actual case
closures by 102 cases and increased other region’s closures by varying
amounts that totaled 102 cases.
25. After reading the inaccurate reports, Wallace felt they were not truthful and
did not acknowledge all of the cases closed by Capital Region.
26. From May to September 2014, Wallace challenged to Sharp and Hughes the
inaccurate reports generated by the Legal Department and by an inaccurate
computer case tracking system (CTS), in which erroneous reports were being
created for internal and external dissemination. The CTS was unable to
account for the transfer of cases from the respective Regions’ databases to
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Capitol Region’s database. Hence, the CTS also was unable to credit Capitol
Region for successfully closing the cases transferred from the other Regions.
Although the secretaries of the respective Regions manually prepared
accurate monthly reports, Hughes and Sharp instead relied on the inaccurate
CTS reports.
27. For example, on June 24, 2014 Wallace sent an email to Hughes in which she
stated “I trust you understand and appreciate the ongoing and annoying
problem of inaccurate data reporting and will do everything to make sure staff,
Charlie included, report accurate Region by Region reports for Agency as well
as public consumption.”
28. Similarly, on July 25, 2014, Wallace sent an email to Hughes and Sharp in
which she noted that the closure report for the Capitol Region was incorrect
and requested that it be corrected. That same day, Wallace had a telephone
conversation with Sharp in which Sharp stated that the case closure reports
were none of Wallace’s concern. Wallace replied by stating that she would
continue to raise objections to such inaccurate reports.
29. On July 27, 2014, Wallace emailed both Hughes and Sharp, again objecting
that the case closure reports were inaccurate, stating: “The report generated
by [DAS]/Chris is wrong. [DAS] is aware of its inaccuracy. The CTS report is
now being relied on as The Agency official report credits cases closed by
Capitol Region to the Regions where the cases originated. . . . Obviously,
Tanya, the CTS cannot serve as the Agency official enforcement report,
because it is unable to reconcile [cases] originated in other Regions and were
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closed by Capitol Region.”
30. Despite Wallace’s many objections, Sharp and Hughes used incorrect
information generated from the CTS system to disseminate inaccurate case
closure reports.
31. The use and dissemination by CHRO of false case closure statistics
unquestionably is an important matter of public concern. CHRO has a long
history of using case closure reports to measure the success of the various
Regions. In addition, the Connecticut General Assembly evaluates the
productivity and claim frequency in the various CHRO Regions in assessing,
inter alia, whether to close particular regional offices and in fashioning
legislation addressing CHRO case processing.
32. A subsequent investigation by the Connecticut General Assembly’s
Legislative Program Review and Investigations Committee found that
Wallace’s complaints were correct, in that the CTS was under-reporting the
aged cases in the regions and not reporting aged cases assigned to the Legal
Division.
33. It was not part of Wallace’s ordinary job duties to challenge the use and
dissemination of false case closure statistics to Sharp and/or Hughes.
C. The History of Harassment and Retaliation
34. Sharp and Hughes were angered by Wallace’s objections to their
dissemination of inaccurate case closure reports. Sharp advised Wallace that
the reports generated by Administration were none of Wallace’s concern.
Wallace advised Sharp that she would continue to respond to any inaccurate
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case closure reports that she received.
a. Unwarranted investigation based on false accusation that

Wallace claimed other regions were “stealing” credit for cases
closed by Capital Region
35. At a routine staff meeting on September 18, 2014, Wallace explained to her
staff that the CTS system was broken and that cases transferred to Capital
Region and resolved by Capitol Region, were never transferred from the
respective databases of the other Regions and hence the resolutions of those
cases were incorrectly credited to the Regions from which they were
transferred.
36. Wallace further explained to the staff that while the CTS reports were
incorrect, the Capitol Region was reporting the accurate data to the
Administration.
37. On September 22, 2014, Sharp advised Wallace that she would be at the
Capitol Region office the following day to investigate whether Wallace had
stated during the staff meeting that the Legal Department was “stealing” credit
for Capitol Region’s cases.
38. Wallace denied using the term “stealing” and explained what she actually said
during the staff meeting. Wallace stated that her concerns over the inaccurate
reporting of the Capitol Region’s performance for many months by
Administration were no secret and she questioned the point of such an
“investigation.”
39. The following day Sharp and Hughes appeared at the Capitol Region offices
and proceeded to place everyone in the office under oath and to subject
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everyone to lengthy interrogations.
40. This was very disruptive and intimidating to the staff and unquestionably
undermined Wallace’s position as the Regional Manager.
41. Sharp and Hughes interrogated Wallace’s administrative assistant, Dedra
Morris, who refuted the allegation against Wallace.
42. Immediately following their interrogation of Dedra Morris, Sharp and Hughes
advised Ms. Morris that they were cutting her overtime hours in half.
43. The immediacy of this retaliation against a witness supportive of Ms. Wallace
was unmistakable. Ms. Morris had been working overtime because of the
very high volume of work in Capital Region and because the office assistant
position for the Capital Region had been vacant since June 2014. The other
Regions, like West Central, were fully staffed with at least two support staff
persons and were receiving approved overtime at the same time that Ms.
Morris’s overtime was cut in half.
44. On October 6, 2014, Wallace reported this unnecessary and harassing
“investigation” to the Department of Labor, which serves as the Human
Resources Department for CHRO. The Department of Labor advised Wallace
that it was improper to place staff under oath in that type of investigation.
45. In connection with her complaint on October 6, 2014, Wallace notified the
Department of Labor that Sharp and Hughes had refused to pay Dedra Morris
for the eight hours she worked on Saturday, May 29, 2014, calculating case
closures. The Department of Labor immediately directed that CHRO pay Ms.
Morris for her work.
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46. On October 2, 2014, Sharp and Hughes appeared in Wallace’s office
unannounced, intending to interrogate her. They entered Wallace’s office
without knocking while her back was turned, and she was working on the
computer. When Wallace first noticed them, they were standing at her desk.
The fact that Sharp and Hughes would appear at Wallace’s office
unannounced intending to conduct a lengthy interrogation demonstrates their
total disregard for professional office interactions in favor of inflicting
unwarranted stress and harassment on Wallace.
47. On November 13, 2014, Wallace submitted a Freedom of Information request
to the CHRO seeking documentation relating to the “investigation” and copies
of any complaints against her. Sharp and Hughes chose not to respond to
Wallace’s Freedom of Information request and have not done so to this date.
b. Unfounded Complaint by Felipe M.
48. On November 20, 2014, Complainant Felipe M. met with a disgruntled
investigator and union steward assigned to Capital Region, Daniel Salerno.
On information and belief, Mr. Salerno encouraged and assisted Felipe M. in
preparing a complaint against Wallace alleging that Wallace: (1) prevented
Mr. M. from filing any amended discrimination complaints; and (2) bullied and
bad-mouthed Mr. M. and employees in the Capital Region office.
49. In support of his claim of bullying and bad-mouthing, Mr. M. had attached an
email Ms. Wallace sent him and his attorney more than two years earlier on
July 25, 2012. The email stated as follows:
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“Mr. M.:
Mediation Conference has long taken place. I have no further

obligation to convene yet a third [m]ediation conference. Your
attorney, Anthony DiMarco, does not convey the impression he
wishes to be engaged. He sits non-responsive, then hurriedly
leaves, with you running to catch up with him because “he is your
ride.” You seem to be speaking for your attorney, a reverse in roles
I do not understand. Everything in the proposed settlement
agreement is exactly as I have discussed it with you and your
attorney. You both agreed to the terms at the time I discussed them
with you. If you have comments on the draft, please have Att.
DiMarco put them in writing to the Respondent’s attorney, Tom Clark.
I do not see any communication coming from your attorney to me or
to the respondent, therefore I do not find it credible that Attorney
DiMarco has, on numerous occasions, reached out to Attorney Clark
without luck. I will afford you and your attorney yet another 2 weeks
to come to an agreement on the proposed settlement offer. Failing
this I will schedule a fact-finding conference. Thank you.
Sincerely,
Pekah Wallace
Regional Manager
50. This email from years earlier contained no bullying or badmouthing. Nor has
Wallace ever treated Mr. M. other than professionally. The email from years
earlier related to a prior complaint that M. had filed in 2012 in the Waterbury
Region and which Wallace had successfully settled.
51. In fact, Mr. M. was grateful to Ms. Wallace for her assistance and wrote her to
thank her on July 27, 2012, stating, in pertinent part:
Dear Mrs. Pekah Wallace:

I wish to thank you in advance for helping me and my Attorney
DiMarco settle with Attorney Tom Clark. . . .
I once again thank you for Exemplary Services in helping this
very important cause. May God Bless you greatly for your
patience and good will always.
Sincerely,
Felipe M.
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52. On information and belief, Mr. Salerno provided the complaint against
Wallace, which he helped Mr. M. prepare, to Sharp, who filed the complaint
against Wallace with the Department of Labor, despite her knowledge that the
complaint was unfounded.
53. Although claiming that he was denied the opportunity to file an amended
discrimination complaint, Mr. M. in fact filed an amended complaint of
discrimination on November 20, 2014. Wallace had had no interactions with
Mr. M. in connection with his filing of an amended complaint on November 20,
2014 other than to say hello as she passed by while Dedra Morris was
assisting him.
54. On November 25, 2014 at 8:31 a.m., Sharp sent an email to Wallace advising
her that she received a complaint from Mr. M. claiming that Wallace prevented
him from filing an amended complaint and bullied him and the staff assigned
to work with him.
55. On November 25, 2014, Wallace responded to Sharp that she had not
interacted with Mr. M. other than to say “hello” and that he had, in fact,
amended his complaint with the assistance of Ms. Morris and Mr. Salerno.
Ms. Wallace attached a copy of Mr. M.’s amended complaint proving that Mr.
M. had been allowed to amend his complaint.
56. Sharp seized on this groundless complaint as a means to retaliate against
Wallace on November 26, 2014 by forwarding Mr. M.’s complaint to the
Department of Labor for investigation, without including Wallace’s response or
advising the Department of Labor that she had proof that Mr. M. had, in fact,
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been permitted to amend his complaint. Ms. Sharp did not forward a copy of
the amended complaint to the Department of Labor.
57. Wallace was notified by the Department of Labor on December 30, 2014, that
it was investigating her, but was not told the nature of the complaint or identity
of the person who filed the complaint. The Department of Labor did not
reveal the nature of the complaint until they met with Ms. Wallace to
interrogate her on January 16, 2015 and revealed that the investigation
related to a complaint by Felipe M.
58. Wallace asked Hughes if she knew what the investigation was about, and
Hughes disingenuously claimed not to have any knowledge of an
investigation.
59. Although Sharp was aware that Mr. M. had in fact filed an amended
discrimination complaint on November 20, 2014, she made no attempt to
advise the Department of Labor that Mr. M.’s complaint falsely alleged that
Wallace had prevented him from filing amended complaints.
60. Likewise, although the email attached to Mr. M.’s complaint was more than
two years old and evidenced no bullying or badmouthing, Sharp made no
effort to communicate to the Department of Labor that the complaint lacked
factual support.
61. Instead, Sharp chose to subject Wallace to a formal Department of Labor
investigation regarding allegations she had reason to know lacked merit.
62. Neil Griffin, who investigated the complaint for the Department of Labor,
never issued an investigative report regarding its investigation, despite the
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clear evidence that the complaint had no merit.
63. Despite the lack of an investigative report, Sharp used Mr. M.’s complaint to
issue Wallace a poor performance review.
64. Specifically, in Wallace’s performance review, Sharp included the following
negative comment: “During this rating period there have been staff complaints
and complaints from the public. There are currently several on-going
investigations being conducted into your actions regarding members of your
staff and the public.”
65. Wallace grieved the performance review and during the initial grievance
hearing Sharp admitted that she had relied on the complaint by Mr. M. and
the investigation she initiated to support the negative performance review.
66. There were no other complaints from the public and neither Hughes nor
Sharp was able to identify any. Further, Neil Griffin confirmed that it is
impermissible for a supervisor to rely on conduct outside the rating period to
issue a negative performance rating. Moreover, the mere existence of an
investigation into unfounded allegations cannot form a basis for a negative
evaluation.
c. Investigation into Wallace’s attendance
67. In April 2015, Wallace learned that an investigator in the Capitol region office was
conducting a personal real estate business on state time using his state computer.
68. Wallace brought this issue to Sharp’s attention, but Sharp never got back to her.
69. In response, Wallace sent an “office protocol” memorandum to the Capitol Region.
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70. Shortly thereafter, Sharp emailed Wallace to question her about the “office protocol”
email.
71. Wallace responded with a memorandum to Sharp that specifically mentioned the
allegation of an employee using work time to conduct a side business.
72. This memorandum stated: “I reminded you of the prior occasion I had brought to
your attention the very conduct of the individual concerned” and “In our conversation
today I also reminded you that this same issue had come up previously when DAS
personnel had mistakenly accessed this particular employee’s PC and discovered
him engaged in similar non-work-related activity and that nothing was done, despite
your knowledge and Tanya’s.”
73. No investigation was conducted into the employee who was performing personal
work on state time using his state computer.
74. Sharp’s response was to order an investigation into Wallace’s attendance.
d. Complaint by Daniel Salerno regarding alleged discussion of

his performance with Dedra Morris
75. On June 19, 2015, acting in her capacity as his supervisor responsible for
reviewing his work product, Wallace completed a review of a draft
investigative summary prepared by Daniel Salerno and identified several
areas in need of substantive correction. Wallace’s recommended changes
caused paragraphs to shift outside the margins and/or not be numbered at all.
Therefore, Wallace asked Dedra Morris, her administrative assistant, for her
assistance to adjust the formatting of the document.
76. Wallace’s discussion with Ms. Morris was limited to rearranging the prepared
text to conform to the proper margins. Ms. Morris and Wallace were able to
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make many of the corrections but, realizing that the paragraphs would likely
shift again once Mr. Salerno made the recommended changes, they thought it
best to leave the remainder of the corrections in place, to be completed by
Ms. Morris in preparation for service. During the discussion, Wallace did not
provide any commentary regarding Mr. Salerno’s job performance.
77. On June 19, 2015, Daniel Salerno, the disgruntled investigator and union
steward, who in the past had filed two grievances against Wallace that were
both denied by the Department of Labor for lack of merit, complained to
Sharp alleging that he overheard Wallace making comments to Ms. Morris
about his performance.
78. Sharp seized on this complaint by Mr. Salerno as an excuse to conduct yet
another full-scale investigation of Wallace.
79. Sharp appeared at the Capital Region on June 21, 2015 and proceeded to
interrogate Wallace and her entire staff over two days.
80. On June 23, 2015, Wallace explained to Sharp what had taken place and that
Mr. Salerno could not possibly have overheard any discussion of his
performance because no such discussion took place.
81. Mr. Salerno admitted that he had not heard the exact discussion between
Wallace and Dedra Morris because he was not close enough to hear their
discussion.
e. Retaliatory meeting with Daniel Salerno and Cheryl Sharp
82. Not satisfied with the outcome of his complaint that Wallace had discussed
his performance with Ms. Morris, Mr. Salerno next complained to Sharp that
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he objected to the substance of Wallace’s suggested revisions to the same
investigative summary that was the subject of his prior complaint.
83. The investigative summary prepared by Mr. Salerno was replete with
conjecture, witness testimony poorly analyzed or glossed over, unsupported
conclusions, and key witnesses never contacted. The purported findings of
fact were instead a collection of conclusory statements. Wallace provided Mr.
Salerno with suggested revisions to his initial draft and to a second draft for
the purpose of correcting those issues.
84. Sharp directed Wallace to meet with her and Mr. Salerno on August 21, 2015.
Mr. Salerno was aware that the purpose of the meeting was to address his
complaint regarding the substance of Wallace’s suggested revisions to his
work. Wallace, however, was not aware of Mr. Salerno’s complaint and Sharp
did not advise Wallace of the purpose of the meeting other than to reference
the case name.
85. When the meeting started, Wallace realized the purpose and objected to
being questioned about her review of Mr. Salerno's work product in front of
Mr. Salerno, her subordinate. Sharp immediately cut Wallace off before
Wallace had a chance to explain the grounds of her objection, left the room
and returned with Monica Richardson, an administrative assistant, to sit in on
the meeting. As she re-entered the room she announced, “Your objections
are noted!” Sharp never allowed Ms. Wallace the courtesy to explain her
objections.
86. In conducting the meeting in this manner, Sharp undermined Wallace’s
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authority as manager in front of Mr. Salerno and Ms. Richardson and
compromised Wallace’s ability to manage him.
87. Prior to the meeting, Sharp had not conferred with Wallace regarding her
revisions to the draft summaries and had not read her suggested revisions.
The meeting was predicated solely on Mr. Salerno’s complaint.
88. During the meeting, Mr. Salerno admitted that he had not addressed the
second review and edits since Wallace had returned those revisions. He had
made none of the revisions Wallace returned to him on June 21, 2015.
89. Sharp asked what Wallace meant by her comment that paragraph #4 was
“conclusory...” After initially showing a reluctance to allow Wallace access to
the draft decision, Sharp reluctantly allowed her to read the paragraph aloud.
Wallace explained not only was the paragraph not a “finding of fact,” but that
the flaws in Mr. Salerno’s work were so obvious that they could not be denied.
90. Having heard paragraph #4 read aloud, Sharp had no choice but to find that
although intended as a finding of fact, paragraph #4 was indeed conclusory.
Sharp conceded, “Pekah is right.” Sharp then explained to Mr. Salerno what
was wrong with his summary decision. Rather than accept Sharp’s
instructions, Mr. Salerno went on an extended diatribe concluding “you
[Sharp] are in the yo-zone,” and other mutterings such as “this was the wrong
case to start with.” Sharp made no response to Mr. Salerno’s insubordination.
91. The fact that Sharp hauled Wallace into a meeting to review her work in the
presence of her subordinate and an administrative assistant without first
reviewing Wallace’s work or conferring with Wallace further demonstrates her
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intention to seize on any opportunity to harass and retaliate against Wallace.
f. Retaliatory response to J.C. complaint
92. On or about May 11, 2016, Wallace instituted a safety procedure requiring a
frequent complainant, J.C., to submit his notarized CHRO complaints to the
Capitol Region Office by mail and restricting his access to the Capitol Region
office.
93. This safety procedure was instituted because of aggressive and threatening
behavior exhibited by J.C., and was instituted with the full knowledge and
concurrence of Sharp and Hughes.
94. On or about July 8, 2016, Spencer Hill called Wallace at Sharp’s direction to
inquire as to why the Capitol Region Office would not meet with J.C. to
notarize his complaints.
95. Wallace responded by informing Hill of the security procedure that had been
put in place regarding J.C., with the full knowledge of Sharp and Hughes.
96. Shortly thereafter, J.C. appeared at the Capitol Region Office with two un-
notarized complaints. Wallace declined to send a staff member down to meet
with J.C. in person.
97. Sharp then took it upon herself to interrogate Wallace at length. Sharp
demanded to know which investigators had complained about J.C., and
implied that there were no such complaints.
98. Although J.C.’s complaint obviously had no merit, Sharp and Hughes referred
his complaint to the Department of Labor for yet another formal investigation
into Wallace with a view towards discipline.
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99. On or about August 12, 2016, Wallace filed a formal complaint with CHRO’s
Board of Commissioners regarding unsafe working conditions and retaliation
by, inter alia, Sharp and Hughes based on their handling of the J.C.
complaint.
100. CHRO took no action in response to this complaint.
g. Retaliatory investigation and write-ups
101. On April 24, 2017, Charles Perry, a paralegal in CHRO’s legal department,
filed a complaint with Sharp and Hughes that Wallace had been rude to him
while he was in the Capitol Region office making copies.
102. That same day, Sharp sent an email to Wallace about the complaint, directing
that Wallace provide an account of her interaction with Perry. Wallace
immediately responded.
103. On Friday, April 28, 2017, Sharp and Hughes embarked on a full-scale
investigation, interrogating Wallace and her staff for several hours.
104. During her interrogation of Wallace, Sharp repeated her questions numerous
times.
105. As a result of Sharp’s relentless interrogation, Wallace had an anxiety attack,
to the point where she needed to seek medical advice.
106. Sharp then returned with Hughes to “finish the investigation.” Both Sharp and
Hughes spent approximately an hour hurling questions at Wallace, often
simultaneously, without regard to Wallace’s well-being. At one point, Hughes
stated “This is not Pekah’s little sanctuary.”
107. On Monday, May 1, 2017, Sharp issued Wallace a “Counseling Memorandum
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for Job Performance” in which she accused Wallace of unsatisfactory
performance, failure to follow a directive to answer “simple, routine questions”
during her investigation of the Charles Perry matter and insubordination.
Sharp further stated that Wallace demonstrated a “lack of cooperation” during
the investigation, and accused Wallace of “unnecessary escalation” and
“simulated crying.”
108. Three days later, on May 4, 2017, Sharp and Hughes issued a second
“Written Counseling Memorandum for Job Performance” relating to her
interaction with Charles Perry. This counseling memorandum included a list
of 32 unsupported allegations of misconduct by Wallace in her brief
interaction with Perry, to which Wallace was not given an opportunity to
refute.
109. On June 3, 2017, Wallace filed a complaint with CHRO’s Board of
Commissioners against Sharp and Hughes regarding their conduct in the
investigation and the issuance of the two counseling memoranda. CHRO
referred this complaint to Griffin at the Department of Labor.
110. Griffin issued a report of his investigation into Wallace’s complaint on
September 8, 2017, concluding that there was no evidence that Hughes’s and
Sharp’s interactions with Wallace were retaliatory, while also noting that there
was no evidence that Wallace had been hostile in her interactions with Perry.
111. On October 10, 2017, Cherone Payne, Chair of the CHRO Board of
Commissioners, sent a letter to Wallace dismissing her complaint against
Hughes and Sharp, without Wallace having been given an opportunity to
23
rebut the many inaccuracies in Griffin’s report.
h. Retaliatory performance review
112. Sharp met with Wallace on or about December 12, 2017 to provide her the
quarterly Performance Assessment and Recognition System (“PARS”)
review.
113. During that meeting, Sharp disclosed that she was issuing Wallace a rating of
“needs improvement” in the performance category of compliance with
statutory time frames. Specifically, Sharp falsely claimed that in 44% of the
cases assigned to the Capital Region during the period from July to
September 2017, the mediations were not scheduled within 60 days of the
Case Assessment Review (“CAR”) retentions.
114. Contrary to that accusation, in 100% of the cases in the Capital Region the
mediations were scheduled simultaneously with the CAR retentions in total
compliance with the statutory requirements. Further, although not required,
nearly all mediations were held, not just scheduled, within the 60 days of CAR
retentions or shortly thereafter.
115. By achieving 100% compliance with the statutory scheduling timeframes,
Wallace provided outstanding service to the public and she exceeded
expectations in this performance category by holding nearly all mediations
within 60 days, which is more than required by the statute.
116. During the PARS discussion with Wallace, Sharp stated that she suspected
that the data she relied on to rate Wallace’s performance as “needs
improvement” was inaccurate, because the other Regions had only “one or
24
two” mediations not scheduled within the 60-day timeframe. Despite her
doubts as to the accuracy of the data upon which she was relying, Sharp
proceeded to issue the “needs improvement” rating.
117. Wallace immediately pointed out the glaring errors in Sharp’s claims and
asked Sharp to disclose the data upon which she was relying. Sharp initially
agreed to disclose the data upon which she had relied but subsequently
refused to disclose the data.
118. Instead, Sharp directed Wallace to prove her wrong.
119. Within a few days, on December 15, 2017, Wallace provided a detailed report
to Sharp based on the official CTS database proving that every mediation in
the Capital Region was scheduled within the 60-day statutory timeframe.
120. This report did not include any facts of the cases, copies of complaints,
opinions or conclusions of investigators, conclusions of the Regional
Managers, or communications between investigators and the parties.
121. Wallace copied her attorney, Miguel Escalera, on the December 15, 2017
email to Sharp that included the report.
122. Sharp refused to correct the false performance review or disclose the faulty
data upon which she relied.
123. In her response to Sharp, Wallace respectfully requested that the erroneous
PARS be corrected and further requested that Sharp stop the retaliation
against her.
25
124. In response, Sharp directed Griffin at the Department of Labor to investigate
Wallace for her objections to her PARS rating, including her objection to
retaliation.
125. Wallace subsequently received a notice from Griffin advising her that she was
the “subject” of an investigation.
126. When she appeared before the Department of Labor for the investigation on
January 19, 2018, Griffin explained that she was being investigated for her
objection to the PARS rating and that the investigation included her allegation
of retaliation.
127. Referring an employee’s objection to a false performance evaluation and an
employee’s allegation of retaliation to the Department of Labor for a formal
investigation is improper, and continues a pattern of Hughes and Sharp using
false allegations against Wallace to subject her to unwarranted and punitive
investigations and unsubstantiated negative performance reviews.
128. At the investigatory interview on January 19, 2018, Griffin presented Wallace
with a chart prepared by Sharp erroneously reflecting 188 cases for CAR
retention in the Capital Region. The correct number of CAR retentions was
84 (99 cases minus 13 cases transferred to the Legal Department and minus
2 Requests for Reconsideration = 84 total CAR retentions). Sharp’s chart also
erroneously claimed that 44% of the mediations in the Capital Region were
not scheduled within 60 days when in actuality none of the mediations in the
Capital Region were scheduled more than 60 days after CAR retention.
26
i. Retaliatory suspension from work
129. Wallace received a written notification from Griffin on January 2, 2018
advising her that she was the subject of an investigation regarding her
objections to the Quarterly PARS for the period July to September 2017.
130. In advance of the investigatory interview with Griffin on January 19, 2018,
Wallace forwarded him a copy of the report she had prepared at the direction
of Sharp demonstrating that the Capital Region had met all mediation
scheduling timeframes.
131. On January 19, 2018, Griffin presented Wallace and her attorney, Miguel
Escalera, with a copy of the reports he had received from Wallace.
132. During the meeting, Wallace explained the reports to Griffin, which clearly
demonstrated that Capital Region was 100% compliant with statutory
timeframes.
133. On information and belief, on January 19, 2018, Griffin provided Hughes and
Sharp a copy of the digital recording and transcript of his interview with
Wallace in which she described her claim of retaliation and further alleged, for
the first time, that she has been subjected to discrimination.
134. Following the meeting, on January 23, 2018, Griffin, acting at the direction of
Hughes and Sharp, asked Wallace to explain whether she believed that she
has been subjected to discrimination by Hughes and Sharp.
135. Wallace responded to Griffin on January 23, 2018, in part, as follows:
Cheryl and Tanya have retaliated against me for having

objected to their falsification of case processing data and
public dissemination of false data, going back to 2014. Since
that time, they have contrived to undermine my work and my
27
relationship with my staff. They have filed multiple false

complaints against me with the Department of Labor and have
issued me unfair performance evaluations based on false
allegations.
136. On information and belief, Griffin immediately provided Hughes and Sharp
with a copy of Wallace’s response and with the transcript of her investigatory
interview in which she further detailed her allegations of retaliation.
137. On January 29, 2018, Wallace learned from Dedra Morris that Hughes wanted to
meet with Wallace in Hughes’ office at 4:00 pm.
138. Wallace sent an email asking Hughes what the meeting was about, and
asking her to contact Wallace’s attorney if it had to do with the ongoing
investigation by DOL.
139. Wallace was then marched out of her office and placed on administrative
leave and ordered not to communicate with any CHRO employees, with the
exception of Hughes and Sharp.
j. Retaliatory expansion of the investigation into Wallace’s

objections to the PARS
140. On February 2, 2018, Attorney Escalera received a letter from Hughes
claiming that Wallace had breached confidentiality and ordering Attorney
Escalera to destroy any copy of the reports Wallace had prepared at the
direction of Sharp.
141. Specifically, Hughes claimed that Wallace had violated Connecticut General
Statute Section 46a-83(j), which provides as follows:
No Commissioner or employee of the commission may

disclose, except to the parties or their representatives, what
has occurred in the course of such endeavors provided
the commission may publish the facts in the case and any
28
complaint which has been dismissed and the terms of

conciliation when a complaint had been adjusted. Each party
and his representative shall have the right to inspect and copy
documents, statements of witnesses and other evidence
pertaining to the complaint, except as otherwise provided by
federal law or the general statutes. (Emphasis added).
142. Hughes and Sharp claimed that the reports that Wallace prepared at the
direction of Sharp to prove that the Capital Region met the statutory
processing timeframes, which were provided to Attorney Escalera by Griffin,
somehow violated this statute.
143. To the contrary, Hughes and Sharp have established an ongoing practice of
providing Attorney Escalera with information on what has occurred in the
course of pending CHRO cases in connection with their efforts to oppose
grievances initiated by Wallace.
144. Hughes and Sharp have repeatedly disclosed information on pending CHRO
cases to Attorney Escalera when it suited their purposes in opposing
Wallace’s objections to their unfair performance reviews.
145. The information included in the reports which Wallace prepared at the
direction of Sharp included only processing dates, and did not include
information as to “what has occurred in the course” of CHRO investigations,
whereas the information that Hughes and Sharp have disclosed to Attorney
Escalera have included descriptions of what has occurred in the course of
pending CHRO cases and the judgments of investigators with regard to
pending issues in those cases.
29
146. The information which Hughes and Sharp have disclosed to Attorney
Escalera falls more closely within the prohibitions of the statute, contrary to
the information Wallace provided.
147. Specifically, on November 4, 2015, Hughes and Sharp provided to Attorney
Escalera and Griffin a large volume of information pertaining to pending
CHRO cases, including the names of complainants; the names of
respondents; the case numbers; the entire text of complaint affidavits; the
date of the complaints; the names of witnesses; the views of investigators that
complainants were not being cooperative; details regarding mediation efforts;
and details relating to CHRO’s mediation strategy.
148. On May 20, 2016, Hughes and Sharp again provided a huge volume of
documents to Attorney Escalera and Griffin in connection with an Employee
Review Board Appeal being pursued by Wallace. That large volume of
materials contained similar information regarding pending CHRO cases.
149. Griffin, acting at the direction of Hughes and Sharp, provided copies of that
information to Attorney Escalera and to the Office of Policy and Management.
150. Hughes, Sharp, and Griffin did not discipline themselves or terminate their
own employment for violating Connecticut General Statute Section 46a-83(j)
by disclosing what had occurred in the course of pending CHRO cases to
Attorney Escalera.
151. Disciplining and terminating the employment of Wallace for allegedly violating
Connecticut General Statute Section 46a-83(h) was a pretext for ongoing
30
retaliation against Wallace for objecting to the use and dissemination of false
case processing reports.
152. On February 13, 2018, Griffin conducted an investigatory interview of
Wallace, at which time he attempted to question Wallace about alleged
personal use of her state-issued computer and email account.
153. Wallace, through counsel, objected both to the expansion of the investigation
and to Griffin’s participation in the investigation, given his role in distributing
confidential CHRO materials to Atty. Escalera as set forth above.
154. On Information and belief, Wallace’s personal use of her state-issued
computer and email account was similar to that of CHRO’s other three
Regional Directors, none of whom were investigated or disciplined for such
personal use.
155. Disciplining and terminating the employment of Wallace for alleged misuse of
state property was a pretext for ongoing retaliation against Wallace for
objecting to the use and dissemination of false case processing reports.
156. On March 12, 2018, Griffin conducted another investigatory interview of
Wallace, at which time he again attempted to question Wallace about alleged
personal use of her state-issued computer and email account.
157. Wallace, through counsel, raised the same objections to Griffin’s participation
in the investigation, and the interview was concluded.
k. Retaliatory termination
158. On March 16, 2018, Griffin issued an investigatory report in which he falsely
claimed that Wallace had transmitted confidential CHRO information to
31
Attorney Escalera through her state-issued email account. Griffin
recommended that Wallace be terminated.
159. On March 29, 2018, Griffin conducted a pre-disciplinary hearing, at which
Wallace, through counsel, objected (a) to Griffin’s participation, as he had a
conflict of interest, in that he himself had provided the allegedly confidential
information to Attorney Escalera, and (b) to the holding of the pre-disciplinary
hearing prior to the conclusion of the pending Department of Administrative
Services’ investigation into Wallace’s claims of harassment and retaliation by
Sharp and Hughes. Wallace also, through counsel, provided a statement
refuting the claims against her.
160. This pre-disciplinary hearing was a sham, in that Hughes and Sharp already
had determined to terminate Wallace, and nothing Wallace could have done
at the pre-disciplinary hearing would have changed that determination.
161. On April 6, 2018, Hughes terminated Wallace’s employment, effective April
20, 2018, falsely stating that Wallace had (a) “deliberately violated policies on
the use of [her] state email account and the state network, by sending
numerous non-business related emails;” (b) “on multiple occasions and in
voluminous amount in violation of C.G.S. 46a-83(J) [she] had released to
Miguel Escalera . . . information on active CHRO cases;” and (c) “that [she]
had acted in an offensive manner to me, Tanya Hughes on January 29, 2018,
when via email, [she] instructed me to contact [her] attorney if I wished to
meet with [her].” Hughes also falsely stated that Wallace presented no new
or mitigating evidence during the pre-disciplinary hearing.
32
162. Hughes terminated Wallace even though she lacked the statutory authority to
do so under Connecticut General Statutes Section 5-240(c), as the CHRO’s
Board of Commissioners has never voted to designate Hughes with firing
authority pursuant to Connecticut General Statutes Section 5-196(3)..
V. COUNT ONE – VIOLATION OF CONNECTICUT GENERAL STATUTES

SECTION 31-51q (AS TO CHRO)
163. Based on the foregoing, CHRO disciplined, discharged or otherwise
discriminated against Wallace because of her protected activity in violation of
Connecticut General Statutes Section 31-51q.
164. Wallace spoke as a citizen on matters of public concern, and said speech
was protected under the provisions of Connecticut General Statutes Section
31-51q, including the First Amendment to the United States Constitution
and/or Sections 3, 4 and/or 14 of Article First of the Connecticut Constitution.
Wallace’s speech also addressed matters relating to official dishonesty and/or
other serious wrongdoing.
165. CHRO was aware of Wallace’s constitutionally protected speech, and
retaliated against her because of that speech.
166. CHRO’s actions have caused Wallace to suffer damages, including, but not
limited to, lost compensation, wages and benefits, damage to reputation,
emotional and physical distress, as well as loss of enjoyment of life.
167. Wallace also has incurred, and continues to incur, attorneys’ fees and costs.
168. CHRO exhibited a reckless disregard for Wallace’s rights, thereby entitling
Wallace to an award of punitive damages.
33
VI. COUNT TWO – RETALIATION BASED ON THE EXERCISE OF FREE

SPEECH IN VIOLATION OF THE FIRST AMENDMENT TO THE UNTIED
STATES CONSTITUTION AND 42 U.S.C. SECTION 1983 (AS TO SHARP,
AND HUGHES)
169. Based on the foregoing, Sharp and Hughes also retaliated against Wallace in
violation of 42 U.S.C. Section 1983 and the First Amendment to the United
States Constitution.
170. Wallace engaged in speech protected by the First Amendment to the United
States Constitution when she reported and protested the use and
dissemination of false and misleading data by Sharp and Hughes.
171. Wallace spoke as a citizen on matters of public concern, and Sharp, Hughes
and Griffin all had knowledge of Wallace’s constitutionally protected speech.
172. As set forth above, Sharp and Hughes each, acting under color of state law,
retaliated against Wallace for having exercised her rights under the First
Amendment to the United States Constitution.
173. The conduct of Sharp and Hughes, as set forth above, violated Wallace’s civil
rights guaranteed by the First Amendment to the United States Constitution
as enforced through 42 U.S.C. Section 1983.
174. As a consequence of the aforesaid intentional retaliation against Wallace by
Sharp and Hughes, Wallace has sustained damages, including, but not
limited to, lost compensation, wages and benefits, damage to reputation,
emotional and physical distress, as well as loss of enjoyment of life.
34
176. The reckless indifference to Wallace’s federally protected rights by Sharp and
Hughes entitles Wallace to an award of punitive damages.
VII. COUNT THREE – DENIAL OF EQUAL PROTECTION OF THE LAWS IN

VIOLATION OF THE FOURTEENTH AMENDMENT TO THE UNTIED
STATES CONSTITUTION AND 42 U.S.C. SECTION 1983 (AS TO ALL
DEFENDANTS)
177. Based on the foregoing, all Defendants, acting under color of state law,
intentionally singled out Wallace for adverse treatment that was entirely
irrational and wholly arbitrary as compared to other Regional Managers
similarly situated to Wallace.
178. There is no rational basis for the disparate treatment to which all Defendants
subjected Wallace.
179. Defendants’ conduct denied Wallace equal protection under the law in
violation of the Fourteenth Amendment to the united States Constitution, as
enforced through 42 U.S.C. Section 1983.
180. As a consequence of the aforesaid denial of equal protection of the laws,
Wallace has sustained damages, including, but not limited to, lost
compensation, wages and benefits, damage to reputation, emotional and
physical distress, as well as loss of enjoyment of life.
182. The reckless indifference to Wallace’s federally protected rights by
Defendants entitles Wallace to an award of punitive damages.
35
VIII. COUNT FOUR – INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

(AS TO ALL DEFENDANTS)
183. Defendants intended to inflict emotional distress on Wallace, or knew or
should have known that emotional distress would likely result from their
conduct.
184. Defendants’ actions were extreme and outrageous.
185. As a consequence of the aforesaid intentional infliction of emotional distress
by Defendants, Wallace has suffered severe and extreme emotional distress
for which she claims damages.
IX. COUNT FIVE – TORTIOUS INTERFERENCE WITH CONTRACTUAL

RELATIONS (AS TO SHARP AND HUGHES).
186. Sharp and Hughes acted out of personal, improper, malicious, vengeful and
retaliatory motives when they took the actions set forth above.
187. Sharp and Hughes were acting outside the scope of their official duties when
they took such personal, improper, malicious, vengeful and retaliatory actions.
188. By doing so, Sharp and Hughes tortuously interfered with Wallace’s
contractual relations with her employer, the CHRO.
189. As a consequence of the aforesaid actions, Wallace has sustained damages,
including, but not limited to, lost compensation, wages and benefits, damage
to reputation, emotional and physical distress, as well as loss of enjoyment of
life.
190. Wallace is entitled to recompense for her damages from Sharp and Hughes in
their individual capacities.
36
X. COUNT SIX – DEFAMATION (AS TO SHARP AND HUGHES)
191. As set forth above, Sharp and Hughes knowingly, intentionally and
maliciously publicized false statements, both verbal and written, regarding
Wallace to, inter alia, the Commissioners of the CHRO, which were harmful
and injurious to Wallace’s business reputation.
192. Sharp and Hughes knew that the statements they publicized regarding
Wallace were false or acted with reckless disregard to their falsity.
193. The false statements that Sharp and Hughes publicized regarding Wallace
were false statements of fact, harmful to Wallace’s professional reputation in
the community.
194. As a consequence of the aforesaid actions, Wallace has suffered damages,
including but not limited to harm to her business reputation, economic losses,
mental anguish, emotional distress, humiliation and embarrassment.
37
XI. PRAYER FOR RELIEF
WHEREFORE, the Plaintiff respectfully requests:
a. Compensatory damages
b. Damages for emotional distress, injury to reputation, loss of self-esteem
and consequential damages;
c. Punitive damages;
d. A permanent injunction reinstating Wallace to her position and preventing
Defendants from taking any further retaliatory actions against her;
e. Costs;
f. Attorneys’ fees, including but not limited to an award of attorneys’ fees
pursuant to 42 U.S.C. Section 1988;
g. Interest; and
h. Such other and further relief as the Court deems just and equitable.
Plaintiff demands a trial by jury on all issues so triable.
PLAINTIFF, PEKAH WALLACE
Anthony J. Pantuso, III

Anthony J. Pantuso, III
Fed. Bar No. ct11638
Law Offices of Anthony J.
Pantuso, III
4 Research Drive, Suite 402
Shelton, CT 06484
203-726-0284
apantuso@pantusolawfirm.com
38
Case 3:19-cv-00391-MPS Document 1-1 Filed 03/14/19 Page 1 of 1
JS 44 (Rev. 06/17) CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS

Pekah Wallace Cheryl Sharp, Tanya Hughes and Connecticut Commission on Human
Rights and Opportunities
(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Anthony J. Pantuso, III, Law Offices of Anthony J. Pantuso, III, LLC, 4

Research Drive, Suite 402, Shelton, CT 06484 203-726-0284
II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
’ 1 U.S. Government ’ 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State ’ 1 ’ 1 Incorporated or Principal Place ’ 4 ’ 4
of Business In This State
’ 2 U.S. Government ’ 4 Diversity Citizen of Another State ’ 2 ’ 2 Incorporated and Principal Place ’ 5 ’ 5
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Citizen or Subject of a ’ 3 ’ 3 Foreign Nation ’ 6 ’ 6

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
’ 110 Insurance PERSONAL INJURY PERSONAL INJURY ’ 625 Drug Related Seizure ’ 422 Appeal 28 USC 158 ’ 375 False Claims Act
’ 120 Marine ’ 310 Airplane ’ 365 Personal Injury - of Property 21 USC 881 ’ 423 Withdrawal ’ 376 Qui Tam (31 USC
’ 130 Miller Act ’ 315 Airplane Product Product Liability ’ 690 Other 28 USC 157 3729(a))
’ 140 Negotiable Instrument Liability ’ 367 Health Care/ ’ 400 State Reapportionment
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& Enforcement of Judgment Slander Personal Injury ’ 820 Copyrights ’ 430 Banks and Banking
’ 151 Medicare Act ’ 330 Federal Employers’ Product Liability ’ 830 Patent ’ 450 Commerce
’ 152 Recovery of Defaulted Liability ’ 368 Asbestos Personal ’ 835 Patent - Abbreviated ’ 460 Deportation
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of Veteran’s Benefits ’ 350 Motor Vehicle ’ 370 Other Fraud ’ 710 Fair Labor Standards ’ 861 HIA (1395ff) ’ 490 Cable/Sat TV
’ 160 Stockholders’ Suits ’ 355 Motor Vehicle ’ 371 Truth in Lending Act ’ 862 Black Lung (923) ’ 850 Securities/Commodities/
’ 190 Other Contract Product Liability ’ 380 Other Personal ’ 720 Labor/Management ’ 863 DIWC/DIWW (405(g)) Exchange
’ 195 Contract Product Liability ’ 360 Other Personal Property Damage Relations ’ 864 SSID Title XVI ’ 890 Other Statutory Actions
’ 196 Franchise Injury ’ 385 Property Damage ’ 740 Railway Labor Act ’ 865 RSI (405(g)) ’ 891 Agricultural Acts
’ 362 Personal Injury - Product Liability ’ 751 Family and Medical ’ 893 Environmental Matters
Medical Malpractice Leave Act ’ 895 Freedom of Information
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’ 210 Land Condemnation ’ 440 Other Civil Rights Habeas Corpus: ’ 791 Employee Retirement ’ 870 Taxes (U.S. Plaintiff ’ 896 Arbitration
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’ 230 Rent Lease & Ejectment ’ 442 Employment ’ 510 Motions to Vacate ’ 871 IRS—Third Party Act/Review or Appeal of
’ 240 Torts to Land ’ 443 Housing/ Sentence 26 USC 7609 Agency Decision
’ 245 Tort Product Liability Accommodations ’ 530 General ’ 950 Constitutionality of
’ 290 All Other Real Property ’ 445 Amer. w/Disabilities - ’ 535 Death Penalty IMMIGRATION State Statutes
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Other ’ 550 Civil Rights Actions
’ 448 Education ’ 555 Prison Condition
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Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
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VI. CAUSE OF ACTION Brief description of cause:
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VII. REQUESTED IN ’ CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
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DATE SIGNATURE OF ATTORNEY OF RECORD
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Wallace 2019

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Case 3:19-cv-00391-MPS Document 1 Filed 03/14/19 Page 1 of 38

UNITED STATES DISTRICT COURT

PEKAH WALLACE : CASE NO.:

Connecticut Commission on Human Rights and Opportunities, for violation of

Connecticut General Statutes Section 31-51q; retaliation against Plaintiff

because of her constitutionally protected speech in violation of the First

Amendment to the United States Constitution, as enforced through 42 U.S.C.

guaranteed by the Fourteenth Amendment to the United States Constitution

and as enforced through 42 U.S.C. Section 1983; intentional infliction of

emotional distress; tortious interference with contractual relations; and

2. Plaintiff, Pekah Wallace (“Wallace”), is an individual residing in the State of

Connecticut. At all times relevant to this Complaint, Wallace was employed

by the Defendant Connecticut Commission on Human Rights and

Opportunities as Regional Manager of the Capitol Region.

3. Defendant, Cheryl Sharp (“Sharp”), is an individual residing in the State of

Connecticut. At all times relevant to this Complaint, Sharp was employed by

the Defendant Connecticut Commission on Human Rights and Opportunities

4. Defendant, Tanya Hughes (“Hughes”), is an individual residing in the State of

Connecticut. At all times relevant to this Complaint, Hughes was employed

by the Defendant Connecticut Commission on Human Rights and

5. Defendant, Connecticut Commission on Human Rights and Opportunities

(“CHRO”) is an agency and instrumentality of the State of Connecticut, duly

times relevant to this Complaint, CHRO was Wallace’s employer.

III. JURISDICTION AND VENUE

U.S.C. Section 1331 because it asserts federal questions under 42 U.S.C.

Fourteenth Amendment to the United States Constitution, and because

claims under Connecticut General Statutes Section 31-51q also present a

pursuant to 28 U.S.C. Section 1332.

occurred within this District.

A. Wallace’s Exemplary Service to CHRO and the Public

9. Wallace was employed by CHRO for over 21 years in a variety of professional

capacities. She served as manager of the Waterbury Regional Office for 11

Throughout her career, Wallace performed at the highest professional level as

measured by the volume and timeliness of case closings, amounts of

recoveries for complainants, increasing staff efficiency, assisting the public,

and creating a positive image of the Commission in the community. Wallace

has been a leader in the use of effective mediation techniques to resolve

cases efficiently and appropriately.

10. Wallace’s initial 6 years with the Commission from 1985-1990 as an

most widely celebrated Executive Director, relied on Wallace to assume

investigation of some of the most difficult, complex, and politically sensitive

cases to minimize exposure and expedite proper resolution of those cases.

return to the Commission to manage the West Central Regional Office

(Waterbury Office) with an emphasis on mediating more cases and

eliminating the Region’s aged inventory. Within 18 months of her arrival,

frames and obtained over $3 million in monetary recoveries for Complainants.

Wallace maintained a standard of timely case closures and monetary

recoveries for complainants unrivaled by any of the other regional offices.

Tempore of the Connecticut General Assembly and Speaker of the House of

Representatives. Wallace also received accolades from various governmental

and community organizations, other members of the General Assembly and

attorneys of both complainants’ and respondents’ Bars.

promotion of equal rights and opportunities for all people.

100 Most Distinguished Black professionals in the State of Connecticut.

15. On November 1, 2013, Wallace transferred from the Waterbury Office to

position as interim Executive Director and Wallace recalls asking Hughes if

16. Wallace created a structure in which investigators would experience greater

Office closed 322 cases.

effective management of her Region.

Complainants and small business owners unable to afford proper legal

representation, and the legal community, have come to rely heavily on

Wallace’s expertise and willingness to make herself available on short notice

public is well served, public perception of CHRO is enhanced, and the

Administration benefits greatly.

providing outstanding service to the public. Her Region consistently

complaints in Wallace’s Region because of her efforts. Her service to the

public has been repeatedly recognized by the Legislature and leading