CHRO Complaint 0001

8/9/2019 CHRO Complaint 0001

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AFFIDAVIT OF ILLEGAL DISCRIMINATORY ffiffiilffiFf$'"C c e zllfig

CHRONO. /oZalcl7

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EEOC NO. 'i$gb'+ ['gs,. ff h'ffi fL My name is Mastda Salohuddin and I reside at 5 *ilInIH

Connecticut.2. My mailing address is the same.3. The Respondent is the City af Ansonio, the Ansonia Police Department and

Chief of Police Kevin Hale located at 253 Main Street Ansonia CT, and 2 Elm StreetAnsonia CT.4. I have been constantly retaliated against since I began my empioyment with the

latest instance occurring on or about October 9,2009. This retaliation consisted of myemployer, the City of Ansonia's Police Department, by and through the decisions andactions of its Chief of Police, Kevin Hale, instituting a baseless, and conveniently timed,internal affairs investigation against me regarding prior conduct on the part of theAnsonia Police Department and Chief Kevin Hale referenced below. Chief Haleordered that I participate and provide an interview regarding alleged conduct that resultedin my arrest and placement on administrative leave as a way to retaliate against me forfiling a prior CHRO complaint that related specifically to actions he has taken while inoffice. In addition, Chief Hale took such action as retaliation for my decision to fight thefalse criminal allegations he personally requested be brought against me. In addition,Defendant Hale treated me differently from all other members of the department as heincluded allegations in this investigation relating to conduct that was a cofilmon practice


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of the department and its employees, conduct which supervisors had approved andconduct for which no other officer had ever been made the subject of an internalinvestigation.5. This all stems from my July 15, 2009 arrest and placement on administrative

leave.6. I believe that my race (African-American), my color (black), my religion (Islam)

ond my previously having oppased discriminatory conduct (ogainst both myself andothers), and my asserting my First Amendment Rights infiling a prior complaint withthe CHRO and speoking out agoinst hk actions relating to me, were in part lactors inthis action. I believe that the respondent violated the following Connecticut GeneralStatutes and Acts listed below.

46a-58(a) a6a-60(a)(1 ) 46 a-60(a)g) a6 a-60(aX7)46-64a 46a-81 46a-80 a6a-60(a)(S)Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. 2000e and theCivil Rights Act of 1991 (15 or more employees)

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COMPLAINTThe parliculars of my complaint are as follows:)

2) My name is Mustafa Satuhuddin and I reside atllGnttFConnecticut.3) My mailing address is the same.4) The Respondent isthe City of Ansonia, the Ansonia Police Departrnent and

Chief of Police Kevin Hale withbusiness addresses of 253 Main Street Ansonia CT, and2Elm Street Ansonia CT.5) I have been constantly retaliated against since I began my employment with the

aforementioned parties with the latest instance occurring on or about October 9,2009.This retaliation consisted of my employer, the Ansonia police Department, by andthrough, its Chief of Police Kevin Hale, instituting an internal affairs investigationagainst me regarding prior conduct on the pa* of the,4 nsonia Police Department andKevin Hale referenced below. Chief Kevin Hale ordered that I participate and providean interview regarding alleged conduct that resulted in my arrest and placement onadministrative leave as a way to retaliate against me for filing a prior CHRO complaint.In addition, Chief Hale took such action as retaliation for my decision to fight the falsecriminal allegations he personally requested be brought against me. In additionDefendant Hale treated me differently from all other members of the department as heincluded allegations in this investigation relating to conduct that was a common practiceof the department and its employees, conduct which supervisors had approved andconduct for which no other officer had ever been made the subject of an internalinvestigation.


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6) I believe that my roce (African-American), my color (black), my religion (Islom)and my prevtoasly hoving opposed discriminutory conduct (ogainst both myself ondothers) were in parl factors in this action. I believe that the respondent violated theproceeding Connecticut General Statutes and Acts listed on the proceeding page.7) The respondent employs more than l5 persons.8) I began working for the respondent in 1993 in the capacity of a police officer.g) All of my performance ratings up to and including the most recent rated me

satisfactory or better and I have received numerous departmental service awards.10) I began part-time employment with the respondent in 1993.I 1) I repeatedly made attempts to obtain a full time position and was denied such a

position for years.12) Eventually I made a complaint in regard to the City of Ansonia's failure to hire

me for a full time position with the NAACP. After making my complaint I wasinterviewed and offered a full time position.13) After obtaining this position I was subjected to constant harassment at the hands

of my superiors. This harassment included racial slurs and derogatory comments.14) In 1998 I filed a complaint with the commission on Human Rights and

Opportunities due to the fact the Ansania Police Departmenl denied me the right to weara beard- A practice that is extremely important to the practice of my religion. I prevailedin this complaint and as a result gained the right to wear my beard.15) In addition to wearing a beard I also was allowed to openly practice my religion

in the form of being allowed to pray at certain times during the day.


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I6) These developments angered my superiors and they took every opportunity toretaliate against me as a result.17) Eventually I decided to exercise my right to engage in union activities and

decided to run for the position of union president.18) My decision outraged my supervisors and as a result they continued to retaliate

against me.19) This retaliation included failing to take action against other employees who were

openly hostile towards me because of my race and initiating and subjecting me tofrivolous intemal affairs investigations, after which I was not only cleared of any wrongdoing but issued an award for the manner in which I conducted myself.20) In July of 2007 a questioruraire was circulated in regard to the Department's

Harassment and Discrimination Policy. This questiomaire asked if I was aware if anyemployee had been subjected to harassment. I answered yes to this question.21) I was then questioned about my answer by Lt. Cota, an officer in a supervisory

capacity and declined to discuss the matter with him but instead asked who other thanhim I could speak rvith.22) A female officer had been the victim of sexual harassment at the hands of a

superior officer and I was a witness to this. I counseled this officer and offered help inany way that I could, againangering my superiors.23) I also spoke out against and supported others individuals in the City of Ansonia

who had their rights been violatedby Ansonia Chief of Police Kevin Hale.24) These actions again angered my superiors, most specifically Ansonia Chief of

Police Kevin Hale.


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" 25) This summer I was accused of stealing a garden hose from the Ansonia Policedepartment.26) This hose was found within the department three days after it was reported

missing by the same individual who had initially reported it missing.27) Despite the fact this hose was found inside the departm ent, Chief of Police Kevin

Hole requested the Connecticut State Police conduct an investigation and that I bearrested.28) I was arrested and placed on administrative leave which continues as of the date

of this complaint.29) I never stole this garden hose as it never left department property.30) In the past town employees have been accused of and admitted to engaging in

thefts and these employees were not arrested.31) With the aforementioned false arrest as a basis, Chief Kevin Hale used his

position as Chief. and the authority vested in that position, to order, that I, pursuant tocontract, actively participate and provide an interview regarding alleged conduct thatresulted in my arrest and placement on administrative leave as a way to retaliate againstme for:

A) Filing a prior CHRO complaint.B) My decision to fight the false criminal allegations he

personally requested be brought against me.32) Defendant Hale treated me differently from all other members of the Departrnent

as he included allegations of misconduct:


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OATHI request the Connecticut Commission on Human fughts and Opportunities to investigatemy complaint- secure for me my rights as guaranteed to me under the above cited lawsand secure for me any remedy to which I may be entitled.

Mustafu Salohuddin being duly sworn, on oath, states that he is the Complainant herein,that he has read the foregoing complaint and knows the content thereof, that the same istrue of his own klowledge, except as to the matter herein stated on information and beliefand that as to these matters he believes the same to be true.Dated at vl/aterbury, connecticut this 2nd day of N}WMBER 2009.

Subscribed and sworn 2nd day of I\

Rob SerafinowiczCommissioner of the Supertor Court (#423695)

CHRO Complaint 0001

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