Case 5:16-cv-00295-D Document 1 Filed 03/28/16 Page 1 of 12

IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF OKLAHOMA
MATTHEW RAY HANKINS,
An Individual and Former Police Chief
of the Town of Lahoma

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Plaintiff,
v.
(1) THE TOWN OF LAHOMA,
An Oklahoma Political Subdivision,
(2) THERESA SHARP,
The Mayor of the Town of Lahoma,
(3) BRIAN HAMEN,
An Individual,
Defendants.

Case No.: CIV-16-295-D

COMPLAINT
COME NOW, Plaintiffs, Matthew Ray Hankins, an individual and former Police
Chief of the Town of Lahoma, by and through his attorney of record, Mr. Chase
McBride, for his cause of action against Defendants state:
JURISDICTION AND VENUE
1. The original jurisdiction of the court is involved to secure protection of and to
redress the deprivation of rights secured by 42 U.S.C. 1983, within the
jurisdiction of the United States and 28 U.S.C. 1331.
2. The all of the unlawful acts alleged below were committed in or around the Town
of Lahoma, Oklahoma located in the Western District of the State of Oklahoma.
Venue is proper according to 28 U.S.C. 1391.
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PARTIES
3. Plaintiff is an individual residing within the United States Western District of
Oklahoma.
4. Plaintiff is the former Chief of Police of the Town of Lahoma, Oklahoma located
within the United States Western District of Oklahoma.
5. Defendant Town of Lahoma is an Oklahoma governmental entity operating as a
municipality that governs the Town of Lahoma Police Department.
6. Defendant Theresa Sharp (Mayor Sharp) is the Mayor of the Town of Lahoma.
7. Defendant Brian Hamen is an individual who resides in or about the Town of
Lahoma, Oklahoma.
STATEMENT OF CLAIMS
8. Plaintiff was hired as a reserve officer by the Town of Lahomas Police
Department on or about July 13, 2014.
9. Plaintiff applied and was interviewed for the position of Police Chief of the Town
of Lahoma sometime prior to August 10, 2015.
10. Plaintiff was hired/promoted to the position of Police Chief of the Town of
Lahoma on or about August 10, 2015.
11. On October 31st, 2015, Plaintiff, acting in his capacity as Police Chief of the
Town of Lahoma, responded to a call to the police department regarding crimes
involving a Ku Klux Klan (hereinafter referred to as KKK) event.

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12. Once the Plaintiff arrived at the scene of the KKK event he encountered Brian
Hamen, Mayor Sharps husband and other friends of the Mayors husband dressed
in traditional KKK garments surrounding a cross.
13. The KKK attendees appeared to be intoxicated while performing a KKK ritual.
14. Plaintiff reported the activities to the Garfield County Sherriff because the KKK
event was taking place outside of the Town of Lahomas city limits.
15. After requested to resign over the incident, Mayor Sharp stated she had no intent
to resign and tried to play the KKK event off as four good ol boys sitting around
drinking and a prank.
16. The KKK event made local and national news and were a public embarrassment to
the Town of Lahoma and specifically to Mayor Sharp.
17. Brian Hamen has been in a previous relationship with an unpaid Reserve Officer
named Nicole Wedel.
18. Plaintiff is now in a relationship with Reserve Officer Wedel.
19. Brian Hamen was charged with Malicious Injury to Property on January 11, 2016
after willfully damaging Reserve Officer Wedels personal vehicle in Garfield
County in case number CM-2016-46.
20. The Town of Lahomas Policy and Procedure Manual, Section 10 entitled
Probationary Period states:
Frequent performance reviews conducted by the appropriate department
head and/or supervisors will be conducted on a regular basis. For the 12th

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month probationary period, the review will take place in the 6th and 12th
months.
21. On February 8, 2016, the Town of Lahoma held its monthly town meeting.
22. The town meeting on February 8, 2016 was the six month review of the Plaintiffs
probationary period as the Chief of Police of the Town of Lahoma.
23. Prior to the February 8, 2016 meeting, the Plaintiff had not had any performance
reviews.
24. At the town meeting on February 8, 2016, the Plaintiff was told he was up for a
raise because his six month probationary period was up but due to the budget the
town could not give him one at that time.
25. At the town meeting on February 8, 2016, the Plaintiff was told his raise would be
tabled and revisited at the following town meeting on March 14, 2016.
26. Nothing at the town meeting on February 8, 2016 was brought up regarding any
poor performance or complaints about the Plaintiff as his position as Chief of
Police other than he was issuing a lot of speeding tickets to locals.
27. Reserve Officer Wedel filed for a Victim Protective Order against Brian Hamen
on March February 29, 2016 in Garfield County in case number PO-2016-49.
28. Brian Hamen in return filed for a Victims Protective Order against Reserve
Officer Wedel on March 1, 2016 in Garfield County in case number PO-2016-51.
29. A hearing on both Victim Protective Orders occurred on March 9, 2016 in front of
Judge Hammontree in Garfield County.

Case 5:16-cv-00295-D Document 1 Filed 03/28/16 Page 5 of 12

30. At the hearing on the Victim Protective Orders, the Plaintiff was requested to
testify.
31. The Plaintiff was asked about and testified to the KKK activities he responded to
on Halloween of 2015.
32. The Plaintiff stated during his testimony that he responded to the KKK activity
and that he witnessed Brian Hamen, the Mayors husband and others dressed at the
event.
33. The Judge dismissed both protective orders after testimony was taken.
34. After the testimony of the Plaintiff, Brian Hamen submitted a Resident Complaint
Form regarding the Plaintiff and his capacity as Police Chief directly to Mayor
Sharp.
35. The allegations in Brian Hamens Resident Complaint Form are false.
36. Mayor Sharp knows the allegations in Brian Hamens Resident Complaint Form
are false.
37. Brian Hamen wrote the Resident Complaint Form with malicious intent as a
response to the Plaintiff bringing up the KKK event during his testimony in the
Victim Protective Order hearing.
38. The Town of Lahoma held a monthly town meeting on or about March 14, 2016.
39. The Plaintiff arrived at the town meeting on or about March 14, 2016 with the
belief he was up for a raise.
40. The Plaintiff was unexpectedly terminated without any notice at the town meeting
on or about March 14, 2016.
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41. The Plaintiff never received any documentation that supports any reason for his
termination.
I.

First Cause of Action Violation of Procedural Due Process under the

Civil Rights Act, 42 U.SC. 1983 - Against the Town of Lahoma and
Mayer Sharp
Plaintiff restates and re-alleges the previous paragraphs and further states as
follows:

42. Section 9 entitled Demotions of the Town of Lahomas Policy and Procedure
Manual states:
The town Board of Trustees may reduce the salary of any employee or
demote an employee to a lower grade subject to the approval of the Board of
Trustees. The Board of Trustees shall furnish a written statement of the
reasons for any such action to the employee at least (5) five days prior to the
effective date of the action
43. Section 24S entitled Separations-Notice of Layoff of the Town of Lahomas
Policy and Procedure Manual states:
The Town Board shall give written notice to the employee of any
proposed lay off and reasons thereto within a reasonable time before the
effective date.
44. Section 25B entitled Discipline Actions Warning and Reprimands of the Town
of Lahomas Policy and Procedure Manual states:

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That after an oral and written reprimand have been given by the employees
immediate supervisor A written reprimand shall be given to the
employee and a copy placed in his or her work file.
45. The Plaintiff had a property interest in his employment as the Chief of Police of
the Town of Lahoma.
46. The Plaintiff did not receive any oral or written notice of his termination until he
was unexpectedly terminated at the March 14, 2016 town meeting.
47. The Town of Lahomas Policy and Procedural Manual acts effectively as legally
binding terms of an employment agreement.
48. Even if the Town of Lahoma is going to terminate an employee during a
probationary period, the Town of Lahoma is still required to follow the policy and
procedure manual in how the notice and termination is to occur.
49. The Town of Lahoma did not follow the requirements of the Policy and Procedure
Manual in their termination of the Plaintiff.
50. Furthermore, the Town of Lahoma did not comply with the Lahoma Police
Departments Police Policies and Procedures Manual in their termination of the
Plaintiff.
51. As a result of the violation, the Plaintiff has suffered damages and has had his
rights violated by the Town of Lahoma and Mayer Sharp.
II.

Second Cause of Action Retaliation - Against the Town of Lahoma and

Mayer Sharp

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Plaintiff restates and re-alleges the previous paragraphs and further states as
follows:
52. Mayor Sharp and the Town of Lahoma were nationally embarrassed by the
attention that the KKK event brought to the town on October 31, 2015.
53. Mayor Sharp was unhappy with the Plaintiffs actions in responding to the KKK
event involving her husband.
54. The Plaintiff was acting in accordance with his duties as Police Chief in his
response to the KKK event and therefore the Town of Lahoma and Mayor Sharp
are forbidden from retaliating for the proper actions.
55. The Plaintiffs testimony regarding the KKK event at the Victim Protective Order
hearing is a protected right and the Town of Lahoma and Mayor Sharp are
prevented from retaliating against the Plaintiff for his testimony.
56. The Plaintiff was fired by the Town of Lahoma and by Mayor Sharp in retaliation
for his actions of responding to the KKK event on Halloween of 2015 involving
the Mayors husband.
57. The Plaintiff was fired in retaliation of the Plaintiffs testimony in the Victim
Protective Order hearing on or about March 9, 2016 in which he was asked and
testified that he witnessed the Mayors husband, Brian Hamen and other friends at
the KKK event.
58. Mayor Sharp made an audibly recorded statement to the Plaintiff regarding his
testimony at the hearing after he was terminated.

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III.

Third Cause of Action Wrongful Termination Against the Town of

Lahoma and Mayor Sharp

Plaintiff restates and re-alleges the previous paragraphs and further states as
follows:
59. The Plaintiff had successfully completed the 6 month time of his probationary
period without any issues oral or written.
60. Although an employee may be terminated without cause during their probationary
period, the termination cannot be in violation of the employee exercising a civil
right.
61. Although an employee may be terminated without cause during their probationary
period, the termination must be performed in accordance with the Town of
Lahomas Policy and Procedure Manual.
62. The Plaintiff was terminated within days of his testimony at the Victim Protective
Order in which he talked about the KKK event and mentioned the Mayors
husband and friends in the Court hearing.
63. The Plaintiff did not receive any notice of his termination as required by the Town
of Lahomas Policy and Procedure Manual.
64. The Plaintiff was wrongfully terminated for exercising his protected right to
testify.
65. The Plaintiff was wrongfully terminated in violation of the terms in the Town of
Lahomas Policy and Procedure Manual.

Case 5:16-cv-00295-D Document 1 Filed 03/28/16 Page 10 of 12

Fourth Cause of Action Defamation/Libel Against Brian Hamen

IV.

Plaintiff restates and re-alleges the previous paragraphs and further states as
follows:
66. Brian Hamen submitted a written Resident Complaint Form to Mayor Sharp the
same day that the Plaintiff testified in the Victim Protective Hearing.
67. Brian Hamen published false claims against the Plaintiff in the report.
68. As a result of these false claims, the Plaintiff has suffered damages.
Fifth Cause of Action Conspiracy - Against Mayer Sharp and Brian

V.

Hamen
Plaintiff restates and re-alleges the previous paragraphs and further states as
follows:
69. Mayer Sharps husband attended the KKK event on October 31, 2015 with several
of his friends including Brian Hamen.
70. Local and national media caught wind of the KKK event and the Mayors
husbands involvement.
71. The national attention to the KKK event was embarrassing to those involved and
to Mayor Sharp.
72. After several months, the news died down and it seemed that the KKK event had
been forgotten to the relief of those involved and to Mayor Sharp.
73. The Plaintiff answered questions regarding the KKK event in his testimony on or
about March 9, 2016 in the Victim Protective Order hearing.

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74. Brian Hamen and Mayor Sharp were angered that the Plaintiff had brought up the
embarrassing issue in Court.
75. Brian Hamen was also angered because the Plaintiff was now in a relationship
with Brian Hamens former girlfriend.
76. Mayer Sharp and Brian Hamen were looking for a way to discredit the Plaintiffs
testimony of the KKK event and to punish him for bringing up the KKK event in
Court.
77. Mayer Sharp and Brian Hamen conspired to try to improperly and unjustly remove
the Plaintiff from his job as the Police Chief of Lahoma by having Brian Hamen
fill out a Resident Complaint Form and giving it directly to Mayer Sharp.
78. Mayer Sharp and Brian Hamen conspired to take actions to attempt to improperly
discredit the Plaintiffs statements.
79. Mayer Sharp and Brian Hamen conspired together and acted in such a way as to
deprive Plaintiff of his property right in his job and liberty interests.
WHEREFORE, Plaintiffs pray this Court award the Plaintiff damages to reinstate
the Plaintiff as the Police Chief of the Town of Lahoma, Oklahoma, actual damages in
lost wages, attorney fees and costs; and further award punitive damages assessed against
Defendants to punish them for their clearly unjust and unconstitutional actions in excess
of $75,000.00.

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Case 5:16-cv-00295-D Document 1 Filed 03/28/16 Page 12 of 12

Respectfully Submitted this 28th day of March, 2016,

__/s/ Chase McBride________________

RICHARD R. RICE, OBA #15129
CHASE McBRIDE, OBA #32061
Rice Law Firm
1401 S. Douglas Blvd. Suite A
Midwest City, OK 73130
(405) 732-6000 / 737-7446 facsimile
Chase@RiceLawFirm.net
ATTORNEY FOR PLAINTIFF
JURY TRIAL DEMANDED
ATTORNEYS LIEN CLAIMED

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Case 5:16-cv-00295-D Document 1-1 Filed 03/28/16 Page 1 of 2

CIVIL COVER SHEET

JS 44 (Rev. 11/15)

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
Matthew
Ray Hankins

DEFENDANTS
The
Town of Lahoma, Theresa Sharp, Brian Hamen

Garfield

(b) County of Residence of First Listed Plaintiff

County of Residence of First Listed Defendant

(EXCEPT IN U.S. PLAINTIFF CASES)

NOTE:

(c) Attorneys (Firm Name, Address, and Telephone Number)

Attorneys (If Known)

Chase McBride, Rice Law Firm

1401 S. Douglas Blvd, Ste. A, Midwest City, OK 73130
405-732-6000

II. BASIS OF JURISDICTION (Place an X in One Box Only)

1

U.S. Government
Plaintiff

Federal Question
(U.S. Government Not a Party)

U.S. Government
Defendant

Diversity
(Indicate Citizenship of Parties in Item III)

Garfield

(IN U.S. PLAINTIFF CASES ONLY)

IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an X in One Box for Plaintiff

(For Diversity Cases Only)
PTF
Citizen of This State
1

DEF
1

and One Box for Defendant)

PTF
DEF
Incorporated or Principal Place
4
4
of Business In This State

Citizen of Another State

Incorporated and Principal Place

of Business In Another State

Citizen or Subject of a
Foreign Country

Foreign Nation

IV. NATURE OF SUIT (Place an X in One Box Only)

CONTRACT

TORTS

110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of Judgment
151 Medicare Act
152 Recovery of Defaulted
Student Loans
(Excludes Veterans)
153 Recovery of Overpayment
of Veterans Benefits
160 Stockholders Suits
190 Other Contract
195 Contract Product Liability
196 Franchise

REAL PROPERTY
210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property

PERSONAL INJURY
310 Airplane
315 Airplane Product
Liability
320 Assault, Libel &
Slander
330 Federal Employers
Liability
340 Marine
345 Marine Product
Liability
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
Injury
362 Personal Injury Medical Malpractice
CIVIL RIGHTS
440 Other Civil Rights
441 Voting
442 Employment
443 Housing/
Accommodations
445 Amer. w/Disabilities Employment
446 Amer. w/Disabilities Other
448 Education

FORFEITURE/PENALTY

PERSONAL INJURY
365 Personal Injury Product Liability
367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
368 Asbestos Personal
Injury Product
Liability
PERSONAL PROPERTY
370 Other Fraud
371 Truth in Lending
380 Other Personal
Property Damage
385 Property Damage
Product Liability
PRISONER PETITIONS
Habeas Corpus:
463 Alien Detainee
510 Motions to Vacate
Sentence
530 General
535 Death Penalty
Other:
540 Mandamus & Other
550 Civil Rights
555 Prison Condition
560 Civil Detainee Conditions of
Confinement

625 Drug Related Seizure

of Property 21 USC 881
690 Other

BANKRUPTCY
422 Appeal 28 USC 158
423 Withdrawal
28 USC 157
PROPERTY RIGHTS
820 Copyrights
830 Patent
840 Trademark

LABOR
710 Fair Labor Standards
Act
720 Labor/Management
Relations
740 Railway Labor Act
751 Family and Medical
Leave Act
790 Other Labor Litigation
791 Employee Retirement
Income Security Act

SOCIAL SECURITY
861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))

FEDERAL TAX SUITS

870 Taxes (U.S. Plaintiff
or Defendant)
871 IRSThird Party
26 USC 7609

IMMIGRATION
462 Naturalization Application
465 Other Immigration
Actions

OTHER STATUTES
375 False Claims Act
376 Qui Tam (31 USC
3729(a))
400 State Reapportionment
410 Antitrust
430 Banks and Banking
450 Commerce
460 Deportation
470 Racketeer Influenced and
Corrupt Organizations
480 Consumer Credit
490 Cable/Sat TV
850 Securities/Commodities/
Exchange
890 Other Statutory Actions
891 Agricultural Acts
893 Environmental Matters
895 Freedom of Information
Act
896 Arbitration
899 Administrative Procedure
Act/Review or Appeal of
Agency Decision
950 Constitutionality of
State Statutes

V. ORIGIN (Place an X in One Box Only)

1 Original
Proceeding

2 Removed from
State Court

Remanded from
Appellate Court

4 Reinstated or
Reopened

5 Transferred from
Another District
(specify)

6 Multidistrict
Litigation

Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):

Title 42, Section 1983

VI. CAUSE OF ACTION Brief description of cause:

Plaintiff's Due Process was violated and his job was taken under color of law

CHECK IF THIS IS A CLASS ACTION

VII. REQUESTED IN
UNDER RULE 23, F.R.Cv.P.
COMPLAINT:
VIII. RELATED CASE(S)
(See instructions):
IF ANY
JUDGE
DATE

CHECK YES only if demanded in complaint:

Yes
No
JURY DEMAND:

DEMAND $

75,000.00

DOCKET NUMBER

SIGNATURE OF ATTORNEY OF RECORD

FOR OFFICE USE ONLY

RECEIPT #

AMOUNT

APPLYING IFP

JUDGE

MAG. JUDGE

JS 44 Reverse (Rev. 11/15)

Case 5:16-cv-00295-D Document 1-1 Filed 03/28/16 Page 2 of 2

INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44

Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading 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. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:
I.(a)

(b)

(c)

Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and
then the official, giving both name and title.
County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".

II.

Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)

III.

Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.

IV.

Nature of Suit. Place an "X" in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI below, is
sufficient to enable the deputy clerk or the statistical clerk(s) in the Administrative Office to determine the nature of suit. If the cause fits more than
one nature of suit, select the most definitive.

V.

Origin. Place an "X" in one of the six boxes.

Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
When the petition for removal is granted, check this box.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing
date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. Section 1407.
When this box is checked, do not check (5) above.

VI.

Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service

VII.

Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.

VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.
Date and Attorney Signature. Date and sign the civil cover sheet.