RETURN:

MAY 19, 2015

JOHN HARWOOD
VS.
CITY OF WEST HAVEN and
EDWARD M. OBRIEN

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SUPERIOR COURT
JUDICIAL DISTRICT
OF NEW HAVEN
APRIL 16, 2015

COMPLAINT

COUNT ONE
1. The plaintiff is an adult citizen of the United States who resides in West
Haven, Connecticut. He is and for more than fourteen years has been employed
by the City of West Haven, Department of Public Works, as a Heavy Equipment
Operator. Until the events hereinafter described, he had an impeccable work
record and his job evaluations always had been satisfactory or better.
2. The defendant City of West Haven is a municipality in the State of
Connecticut.
3. The defendant Edward M. OBrien is the Mayor of West Haven and, as
such, the highest elected official of the City.
4. Beth Sabo is the Director of Personnel and Labor Relations for the City
of West Haven.
5. Kevin McNabola is the Finance Director for the City of West Haven.

6. Deborah Skerritt is an employee of the City of West Haven whose job

responsibilities include preparation and processing of payroll for all employees of
the City of West Haven. She is the sister-in-law of James Morrissey, who is the
Chairman of the West Haven Democratic Party and a political patron of the
defendant OBrien. She also is the President of Local 681 of the American
Federation of State County and Municipal Employees, the West Haven municipal
employees union.
7. Matthew Corbally is an employee of the City of West Haven and a
nephew of Deborah Skerritt. He is a comparatively new employee of the City,
with low seniority, and is classified as a Highway Driver at Level B22A.
8. In 2014, the plaintiff discovered that Ms. Skerritt had illegally
reclassified her nephew from Level B22A Highway Driver at a low seniority level
to Level B28A Heavy Equipment Operator at a high seniority level, thereby
illegally diverting public money in violation of the criminal laws of the State of
Connecticut.
9. In September 2014, the plaintiff reported this wrongdoing to Beth Sabo
and Kevin McNabola. Both of them stated that, because of Skerritts political
power, they could not do anything about it.
9. Two weeks later, the plaintiff again contacted McNabola and asked
what was being done about Skerritts wrongdoing. McNabola told the plaintiff
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that it was not his problem but, rather, was Sabos problem.
10. One week later, McNabola asked the plaintiff whether Sabo had
contacted him. She had not done so.
11. Two weeks later, in October 2014, the plaintiff reported Skerritts
aforesaid wrongdoing directly to the defendant OBrien. Defendant OBrien told
the plaintiff that he already knew about it. He said: We talked to her and she
wont do it again. No disciplinary action of any kind was taken against either
Skerritt or Corbally, no effort was made to recover the money illegally diverted to
Corbally, and the matter was not referred for criminal investigation or
prosecution.
12. On February 6, 2015, an anonymous city employee reported to
defendant OBrien that the plaintiff had that day washed his truck at a city facility
during his lunch hour.
13. On February 11, 2015, the plaintiff was summarily suspended without
pay for one day as punishment. The plaintiff was innocent of any wrongdoing,
but even if he had in fact engaged in the conduct alleged the penalty was grossly
disproportionate given the nature of the alleged offense and the plaintiffs clean
work record.
14. The plaintiff filed a grievance and a meeting was conducted on that
grievance before Beth Sabo on March 13, 2015. In response to the grievance,
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Sabo shouted: I dont give a rats ass! Do you know how much pressure Im
getting from the third floor? Defendant OBriens office is located on the third
floor of City Hall.
15. Two weeks later, Sabo denied the plaintiffs grievance and reaffirmed
his suspension without pay. Her ruling, however, was dated March 13. A copy
was directed to defendant OBrien.
16. Shortly before Sabo made her ruling, the plaintiff telephoned her and
asked why it was taking her so long to rule. She stated that if he were to pursue
his grievance after she ruled, he certainly would prevail; but stated that the third
floor was insisting that he be suspended.
17. As a result, the plaintiff has suffered economic loss and emotional
distress.
18. The actions of the defendants described above violated Section 3151m of the Connecticut General Statutes.
WHEREFORE the plaintiff claims judgment against the defendant City of
West Haven for compensatory damages, punitive damages, attorney fees and
costs.

COUNT TWO
1 - 18. Paragraphs 1 through 18 of Count One are hereby made
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Paragraphs 1 through 18 of Count Two.

WHEREFORE the plaintiff claims judgment against the defendant OBrien
for compensatory damages, punitive damages, attorney fees and costs.

COUNT THREE
1 - 17. Paragraphs 1 through 17 of Count One are hereby made
Paragraphs 1 through 17 of Count Three.
18. The conduct of the defendants described above violated Section 3151q of the Connecticut General Statutes.
WHEREFORE the plaintiff claims judgment against the defendant City of
West Haven for compensatory damages, punitive damages, attorney fees and
costs.

COUNT FOUR
1 - 18. Paragraphs 1 through 18 of Count Three are hereby made
Paragraphs 1 through 18 of Count Four.
WHEREFORE the plaintiff claims judgment against the defendant OBrien
for compensatory damages, punitive damages, attorney fees and costs.

THE PLAINTIFF

BY_______________________________
JOHN R. WILLIAMS (#67962)
51 Elm Street
New Haven, CT 06510
(203) 562-9931
Fax: (203) 776-9494
jrw@johnrwilliams.com
His Attorney

RETURN:

MAY 19, 2015

JOHN HARWOOD
VS.
CITY OF WEST HAVEN and
EDWARD M. OBRIEN

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SUPERIOR COURT
JUDICIAL DISTRICT
OF NEW HAVEN
APRIL 16, 2015

PRAYER FOR RELIEF

The plaintiff claims judgment in an amount greater than fifteen thousand

dollars ($15,000.00), exclusive of interest and costs.

THE PLAINTIFF

BY:________________________________
JOHN R. WILLIAMS (#67962)
51 Elm Street
New Haven, CT 06510
(203) 562-9931
Fax: (203) 776-9494
jrw@johnrwilliams.com
His Attorney