CHARGE OF DISCRIMINATION

Department of Human Rights

Freeman Building PREPARED BY LEGAL COUNSEL
625 Robert St N
St. Paul, MN 55155
651/539-1100 DEPARTMENT OF HUMAN RIGHTS USE ONLY
Toll-Free 1-800/657-3704
Case Number:
TTY 651/296-1283
____________________________________________
Any person claiming to have been discriminated against because of Acknowledged by:
race, color, creed, religion, national origin, sex, sexual orientation,
marital status, disability, age, public assistance status or familial
status, as provided for in Chapter §363A of the Minnesota Statutes in ____________________________________________
the areas of employment, real property, public accommodations, Date Filed: Date Docketed:
public services, education, credit or business contracts may file a
charge within one year after the alleged discriminatory act with the
Minnesota Department of Human Rights at the above address.

1. CHARGING PARTY: 2. RESPONDENT:

County of Ramsey
c/o Shannon Law, LLC Adult Detention Center
310 S. 4th Ave. Ste. 5010 425 Grove St.
Minneapolis, MN 55415 St. Paul, MN 55101

3. The discrimination was because of: 4. The discrimination was in the area of:
color, race employment

5. Describe the discriminatory act, setting forth in statutory language the violation of Minnesota Statutes,
Section §363A.
I am a Pacific Islander American man with brown skin who was employed, during the relevant timeframe, as an
Acting Sergeant at the Ramsey County Correctional Facility – Adult Detention Center. I have worked at Ramsey
County for approximately ten years.

On the afternoon of May 29, 2020, I was working my normal shift, doing checks on the 5th floor of the facility,
where the segregation and high-risk units are. I was informed around 3 p.m. that a very high-profile inmate, the white
former police officer who killed an unarmed black man in South Minneapolis ("high-profile inmate"), was expected to
be processed that afternoon and to be held on the 5th floor. Another correctional officer on the 5th floor at the time,
who was also a person of color, and I were informed that we needed to clean the 5th floor in order to prepare for the
high-profile inmate's arrival. Cleaning the area involved removing urine and other unsanitary materials, which
was not a normal part of my duties as an Acting Sergeant. Nevertheless, the other correctional officer and I began
cleaning as instructed. While we were doing so, a couple white officers came to replace us and said that the
Scheduling Sergeant wanted to see us and to go to the 3rd floor. When we arrived on the 3rd floor, we realized that
the facility's employees of color were all on that floor, and that we had been segregated from the 5th floor.
During the same afternoon, an "A-Team Response" was called, which normally means there is an
emergency and correctional officers are to drop what they are doing in order to assist the affected inmate
and help transport the inmate to the 5th floor. Several officers of color responded to the call, but were
prohibited from taking the inmate to the 5th floor due to the order to segregate.

The Superintendent met with correctional officers later on May 29 and admitted there had been an order to prohibit
officers of color from the 5th floor. He denied he was racist and defended his decision, but said he had nevertheless
changed his mind about the order. In a meeting the following week, the Sheriff, while claiming to address the issue,
also defended the Superintendent, stating he was not racist. Since then, Ramsey County has denied in the press
that there was any truth to the claims that officers of color were prohibited from being on the same floor as the high-
profile inmate.

(OVER)
 (CHARGE OF DISCRIMINATION, PAGE 2)

I believe Ramsey County's actions were discriminatory because they openly singled out and segregated officers of
color because of our skin color. I understood that the decision to segregate us had been made because we could
not be not trusted to carry out our work responsibilities professionally around the high-profile inmate – solely
because of the color of our skin. I am not aware of a similar situation where white officers were segregated from an
inmate. Unfortunately, while the Superintendent's segregation order was the most overtly discriminatory act that has
occurred during my employment, it was not in isolation; the leadership and culture at Ramsey County have
chronically failed to promote the interests of employees of color.

My fellow officers of color and I were, and continue to be, deeply humiliated, distressed, and negatively impacted by
the segregation order. Among other things, I have been so disgusted by the leadership's actions that I gave up
a promotion and pay following the events surrounding May 29th. The order and Ramsey County’s failure to
adequately address it have caused a hostile work environment for officers of color at the Ramsey County
Correctional Facility - Adult Detention Unit.

I therefore allege that the above-named Respondent has discriminated against me in the area of
employment
_____________________ color / race
on the basis of ____________________ in violation of Minnesota Statutes, Section
§363A ;______________.
Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-2; and the St. Paul City Ordinance, Section 183.

I declare under penalty of perjury under the laws of

the United States of America that the foregoing is
true and correct.

__________________________________________

(Signature of Charging Party)

THIS FORM WAS COMPLETED BY:

Bonnie M. Smith #391915

_____________________________________________________________________________________
NAME ATTORNEY REGISTRATION #

Shannon Law, LLC 310 Fourth Ave. S. , Ste. 5010

_____________________________________________________________________________________
ADDRESS

Minneapolis, MN 55415
_____________________________________________________________________________________
CITY, STATE, ZIP
612.206.3793 612.206.3793
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TELEPHONE NUMBER FAX NUMBER