Juab County Lawsuit

Case 2:18-cv-00371-DBP Document 2 Filed 05/07/18 Page 1 of 20
Cameron Platt (Bar No. 16548)

STRINDBERG & SCHOLNICK, LLC
675 East 2100 South, Suite 350
Salt Lake City, Utah 84106
(t) 801.359.4169
(f) 801.359.4313
cameron@utahjobjustice.com
Attorneys for Plaintiff
IN THE UNITED STATES DISTRICT COURT

DISTRICT OF UTAH, CENTRAL DIVISION
R. LYNN MCAFEE,
Plaintiff, COMPLAINT
AND JURY DEMAND
vs.
JUAB COUNTY, a political Civil No. 2:18-cv-00371-DBP

subdivision of the State of Utah,
SHERIFF DOUG ANDERSON, Judge Dustin B. Pead
AND MIKE SEELY an individual,
Defendants.
Plaintiff Lynn McAfee (“Plaintiff” or “Lt. McAfee”), by and through his
attorneys, hereby complains against Defendants Juab County (the “County”),
Sheriff Doug Anderson (“Sheriff” or “Mr. Anderson”), and Mike Seely (“Mr.
Seely”) (Collectively Defendants) as follows:
I. NATURE OF THE CLAIMS
This lawsuit arises from Lt. McAfee’s wrongful termination from Juab
County without just cause and in violation of his Constitutional property rights
1
under the Fifth and Fourteenth Amendments, as provided under 42 U.S.C. § 1983,
Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e, and the Utah
Protection of Public Employees Act, Utah Code Ann. § 67-21 et seq.
II. PARTIES
1. Lt. McAfee resides in the State of Utah, Juab County, and was a
deputy employed by Juab County at all times relevant to the allegations in this
Complaint.
2. Defendant Juab County is a political subdivision of the State of Utah.
3. Sheriff Doug Anderson is a citizen of the State of Utah and is the
Sheriff of Juab County. Sheriff Anderson is being sued in his official and
individual capacities for all available relief.
4. Defendant Mike Seely is a citizen of the State of Utah and is the
Human Resource Director of Juab County. Mr. Seely is being sued in his official
and individual capacities for all available relief.
III. JURISDICTION AND VENUE
5. This Court has jurisdiction over this matter pursuant to 28 U.S.C. §
1331, § 1343 and § 1367.
6. Venue is proper with this Court pursuant to 28 U.S.C. § 1391(b)
because all the employment practices or individual acts alleged to be unlawful
2
occurred within the jurisdiction of this Court and because all Defendants live in the
State of Utah.
7. On March 6, 2018, Lieutenant McAfee served Defendant Juab County
a Notice of Claim pursuant to the Governmental Immunity Act of Utah, Utah Code
Ann. § 63G-7-401 et. seq., alleging that he was wrongfully terminated in violation
of the Utah whistleblower act. Defendant Juab County has not responded to the
Notice of Claim.
IV. GENERAL ALLEGATIONS
1. Juab County recruited and subsequently hired, Mr. McAfee on
October 29, 2015, by Sheriff Anderson to work as the Jail Commander with the
rank of Lieutenant.
2. The County’s job posting for Jail Commander did not indicate that the
position was anything other than a merit service position, as is common with most
public agency law enforcement jobs.
3. When Lt. McAfee accepted employment with the County, the County
again did not inform him that his position was anything other than a merit service
position.
4. The County did require that Lt. McAfee sign a document stating that
new employees were on probation for one year and could be terminated at-will
during this time period.
3
5. Additionally, the letter stated that “[a] copy of the Juab County
Human Resource Policies and Procedures [would] be made available for [Lt.
McAfee] to review.
6. Unfortunately, the County did not provide the policy manual until
May 12, 2016 upon request by Lt. McAfee.
7. The letter also hinted that after successfully completing probation, and
“if eligible, [Lt. McAfee] may become a merit employee as described in Juab
County Human Resource Policies.
8. Lt. McAfee successfully completed his probationary period and was a
highly competent Jail Commander for the next two years, demonstrating that he
was a dependable employee who was willing to work irregular, on-call, and long
shifts when needed.
9. Significantly, the County treated Lt. McAfee as a merit service
employee, not as an at will employee, consistent with other County lieutenants and
Jail Commanders and in calculating his pay.
a. The County employed two other lieutenants, in addition to Lt.
McAfee, that were both merit service employees.
b. The County paid Lt. McAfee overtime and compensation time,
at time and a half, as a merit service employee when non-merit service
4
employees are only eligible for overtime or compensation time at straight
time according to County policy.
c. The previous Jail Commander, Howard Jacquart whom Lt.
McAfee replaced, was classified as a merit service employee and received
overtime pay as such.
d. John Hunt who was Jail Commander before Howard Jacquart
was a Captain, was classified as a merit service employee, and received
overtime pay as such.
10. Shortly after Lt. McAfee became Jail Commander in 2015, the jail
received a failing evaluation from the Utah State Department of Corrections
(“UDC”) Inmate Placement Program (“IPP”). The evaluation determined that the
jail failed to meet minimum standards. For example, while reviewing jail closed
circuit video the auditors observed a jailer who slept during his shift and failed to
conduct required checks on inmates.
11. Lt. McAfee took immediate steps to correct the deficiencies in the
audit and received feedback from UDC administrators and the Independent Jail
Standards Inspector that “things have never run better.”
12. Throughout his employment as Jail Commander, Lt. McAfee
implemented difficult and often conflicting orders from Sheriff Anderson given the
staffing and budget available to the jail.
5
13. For example, Sheriff Anderson ordered Lt. McAfee to create a
schedule to staff a supervisor at the jail with coverage sixteen hours a day, from
6:00AM to 10:00PM, seven days a week. The implementation of such a schedule
would leave the jail short-staffed during transports of prisoners to court. Lt.
McAfee informed the Sheriff that staffing would not allow such a schedule to
which Sheriff Anderson said, “Well, the road is just going to have to step up!”
14. Unfortunately, Sheriff Anderson failed to pass on his directive to the
supervisors of the road deputies.
15. When confronted at a patrol meeting by the road deputies, Sheriff
Anderson denied any knowledge of requiring the road deputies to perform court
transports.
16. The Sheriff’s actions caused delay and confusion regarding prisoner
transports, seriously affected the morale of both the corrections and road deputies,
pitted each against the other, and wasted public funds and staffing.
17. Sheriff Anderson made other dishonest and disruptive decisions and
statements through Lt. McAfee’s employment at Juab County. In fact, the Sheriff’s
conflicting decisions and denial of those decisions was well known through the
County and within law enforcement.
18. In June 2017, Sheriff Anderson announced he would send all eleven
correctional officers to be Law Enforcement Officer certified (“LEO”) at Peace
6
Officers Standards and Training (“POST”). Lt. McAfee was concerned about the
financial burden this would place on the County, as it would potentially cost
hundreds of thousands of dollars including wages, per diem, and reimbursement
for transportation to the training for all eleven officers. Additionally, the County
would incur additional staffing costs to cover the shifts of these officers.
19. Sheriff Anderson’s decision also carried additional personnel costs.
Due to other agencies’ hiring difficulties, there exists a strong statewide hiring
demand for officers that are already certified as LEOs, prompting better incentives
and higher hourly pay rates.
20. The newly trained corrections officers could immediately seek jobs at
other law enforcement agencies within the state. Lt. McAfee was concerned that
sending all the corrections officers through POST at once would increase the
likelihood of them leaving to other agencies upon completion of the training.
21. A few days after Sheriff Anderson’s announcement, Chief Deputy Al
Taylor (“Chief Taylor”) approached Lt. McAfee and asked him what he thought
about the news of sending the correctional officers through POST.
22. When Lt. McAfee explained his concerns to Chief Taylor, Chief
Taylor got very defensive and responded saying, “You cannot hold people’s
careers back because they might leave.” Lt. McAfee agreed with that statement,
but rebutted Chief Taylor’s view, explaining it was not in the County’s best
7
interest to send corrections officers to unnecessary training that would prompt the
officers to leave because the County would lose valuable employees in whom it
had made significant investment in costs and time.
23. During the next Command Staff meeting, Sheriff Anderson asked
everyone their opinions on sending all corrections officers through POST. Lt.
McAfee was the first to speak, and when he began to express his concerns, Sherriff
Anderson quickly interrupted him saying, “When, I give a directive, why do you
have to always fight everything that I do?”
24. Lt. McAfee responded, “In all fairness, you did not present this as a
directive, you asked what we thought about it. This implied that you wanted our
input.” Then, Chief Taylor came to Sherriff Anderson’s defense and angrily
exclaimed that Lt. McAfee was out of line and that he should not disrespect the
Sheriff.
25. During this exchange, the majority of supervisors present voiced their
opinions in agreement with Lt. McAfee, who then said, “Doug, this meeting is
when we should be able to express our thoughts and views and have a discussion.
When we go out that door and your decision has been made, then we need to
support your decision and be united if we want to remain in our positions.”
26. Lt. McAfee then added that if the County was a business, it would
never spend money and do something that may cause it to lose its employees, or it
8
would go out of business. Ultimately, despite requesting feedback from the staff,
Sherriff Anderson and Chief Taylor refused to listen to the Command Staff’s
comments and chose to implement the training plan.
27. The County permits an environment that is complacent with gender
discrimination and stereotyping towards two female employees jail supervisors:
Sgt. Claudia Newell, and Sgt. Kami Jacobsen.
28. Sheriff Anderson repeatedly referred to Sgt. Claudia Newell as a
“bitch” and stated that he was “sick and tired of Claudia’s attitude.” Lt. McAfee
was uncomfortable with this gender harassment of Sgt. Newell and defended her.
Likely sensing Lt. McAfee’s discomfort, Sheriff Anderson said, “You can’t tell her
I think she is a bitch; you have to sell this for me.”
29. Lt. McAfee also communicated his concerns about Sheriff Anderson’s
gender harassment of Sgt. Newell in a written complaint to HR Director Mike
Seely on August 4, 2017.
30. Following the Sheriff’s example, other officers openly and freely
made various negative and discriminatory comments about female employees. For
example, male officers complained to the Sheriff that neither Sgt. Newell nor Sgt.
Jacobsen should do inmate transfers together because they are both female.
31. Officers also stated that the female sergeants should not be able to
work or even go to lunch together because of their gender, stating they needed to
9
work at different times and shifts, yet all other male supervisors routinely went to
lunch together.
32. Many officers also made negative comments towards Sgt. Newell for
having taken FMLA leave and towards Sgt. Jacobsen for scheduling FMLA leave
in the future.
33. As the ranking supervisor at the jail, Lt. McAfee took measures to
correct officers’ discriminatory comments, but his efforts were negated by Sheriff
Anderson’s conduct.
34. Lt. McAfee tried to talk with Sheriff Anderson on numerous
occasions about the Sheriff’s conflicting orders and resulting chaos, the
mistreatment of the female sergeants, and the difficult work environment
attributable to the Sheriff. Initially, Sheriff Anderson seemed to agree with Lt.
McAfee on the problems he reported and even committed to correcting the issues,
but then failed to take any action to resolve them.
35. Lt. McAfee finally confronted Sheriff Anderson a final time on
August 2, 2017, but Sheriff Anderson refused to speak with him.
36. On August 3, 2017, Lt. McAfee, Sgt. Newell, and Sgt. Jacobsen met
with Mike Seely, the Juab County Human Resource Director, and described the
problems detailed above and Lt. McAfee’s efforts to resolve the problems.
10
37. The following day, Lt. McAfee sent a follow-up letter and
documentation describing his good faith belief that Sheriff Anderson was wasting
or misusing public funds, and potentially violating the law. Lt. McAfee also
described his repeated attempts to resolve his concerns with Sheriff Anderson.
38. Initially, the County and Sheriff Anderson appeared to take Lt.
McAfee’s concerns seriously and reported that it would start an investigation into
the issues he had raised.
39. During the next several weeks, Sheriff Anderson and Lt. McAfee only
communicated when absolutely necessary. On August 29, 2017, Lt. McAfee was in
the Sheriff’s Office parking lot discussing a personnel issue with another
Lieutenant. Sheriff Anderson motioned Lt. McAfee over to his vehicle, engaged in
small talk and asked Lt. McAfee what he was discussing with the lieutenant. Lt.
McAfee explained the personnel issue and then asked Sheriff Anderson if the
conflict between them could be resolved. Sheriff Anderson replied, “I either have
to clear my name or resign.”
40. Lt. McAfee told Sheriff Anderson that there were other options to
resolve the situation besides clearing his name or resigning and said that he just
wanted to do his job without the past conflicts and being threatened.
41. Sheriff Anderson seemed to relax at this point and his tone of voice
softened. He seemed relieved that Lt. McAfee was willing to make compromises
11
and resolve the conflict between them. Sheriff Anderson then admitted that he
“took a look at [himself] in the mirror to see who [he] really is” and that he was
guilty of many of the accusations made by Lt. McAfee in his complaint.
42. The conversation ended on a positive note and Lt. McAfee believed
there was a possibility that the issues he reported would be resolved amicably.
43. Unfortunately Lt. McAfee’s optimism was short lived. On September
13, 2017, Mr. Seely wrote a response to Lt. McAfee’s complaints against Sheriff
Anderson. In the letter, the County denied any remedy to Lt. McAfee because he
did not have standing to file a grievance and threatened his employment by
“counseling [Lt. McAfee] to carefully re-evaluate [his] loyalty to the Sheriff, Chief
Deputy Sheriff and to Juab County.”
44. Incredibly, Mr. Seely “[found] that failure to provide due process is
not a violation of Juab County policy.”
45. The County then told Lt. McAfee, for the first time, that his position
was a career service position and that “Only ‘career service’ employees are
afforded the right to submit a grievance per Juab County Human Resource Policy.”
46. On September 21, 2017, a Millard County investigator interviewed Lt.
McAfee and other jail supervisors as part of a background investigation on a
current Juab County corrections officer. The investigator questioned Lt. McAfee
and other jail supervisors about the corrections officer. A short time later, a second
12
investigator from Millard County requested follow-up interviews with Lt. McAfee
twice and questioned him about whether Lt. McAfee had been truthful in the first
interview.
47. The Millard County investigation was a sham instigated by Sheriff
Anderson against Lt. McAfee for alleged untruthful statements he made to the
investigators to attempt to manufacture just-cause to terminate Lt. McAfee.
However, Lt. McAfee only provided relevant and truthful information.
48. Ultimately, the background check revealed that the corrections officer
had failed to list a theft conviction on his POST application when he was hired by
the County but did disclose the theft when he applied to Sanpete County. POST
opened an investigation into the officer’s applications and ordered that his peace
officer certification be suspended for three years. Despite this ruling, Sheriff
Anderson allowed the officer to continue working at the jail during his POST
appeals.
49. Having created what it felt was sufficient “cause” to terminate Lt.
McAfee’s employment, on November 6, 2017, Sheriff Anderson terminated Lt.
McAfee.
50. The Sheriff told Lt. McAfee that he “had a lot of evidence to back up
the termination” and that “everyone, unanimously agreed.” Sheriff Anderson
13
explained to Lt. McAfee that he was being terminated without cause because he
was an “at-will” employee.
51. Lt. McAfee appealed his termination to Mr. Seely and received a
response dated January 16, 2018, stating again, that his position was at-will and
that he did not qualify for the administrative appeals process.
52. Lt. McAfee continued to seek an administrative appeal of his
termination by sending a written request to both the County Commission and the
Personnel Board, neither of which responded to Lt. McAfee’s request.
53. The County’s termination of Lt. McAfee’s employment deprived him
of wages and the value of lost benefits. His career, reputation, and specific job
prospects have suffered from the disparaging comments and actions of County
officials.
54. In addition, Lt. McAfee has suffered emotional distress and continues
to suffer ongoing mental and physical effects of this situation which has affected
his sleep, his family and personal relationships. [anything else?]
FIRST CAUSE OF ACTION

(Violation of Plaintiff’s Right to Due Process, in Violation of 42 U.S.C. § 1983,
Against Defendants Anderson and Seely in their official and individual
capacity.)
55. Plaintiff incorporates the allegations contained in the paragraphs
above as if fully set forth herein.
14
56. Lt. McAfee had a property interest in his employment and a
reasonable expectation that his employment would continue absent just cause.
57. The County’s termination of Lt. McAfee’s employment violated his
rights to due process of law under the United States Constitution, by firing him and
by denying him adequate pre and post-termination process, which includes notice,
a hearing, and the right to appeal his termination.
58. Despite the County’s refusal to provide him due process, Lt. McAfee
nevertheless exhausted his administrative appeals in the County’s policies.
59. At all times relevant hereto, Defendants acted under color of law
when committing the complained of acts.
60. Defendants’ actions violated Lt. McAfee’s Fourteenth Amendment
rights by depriving him of a property interest without due process.
61. The right to due process is a clearly established constitutional right
which a reasonable person, including the Defendants, would or should have
known.
62. As a result of Defendants’ conduct, Lt. McAfee has been injured, has
suffered, and will continue to suffer losses. Pursuant to 42 U.S.C. § 1983 et seq.,
he is entitled to all available relief, including injunctive and prospective relief,
back pay, reinstatement and/or front pay, and actual and compensatory damages, as
well as costs and attorney’s fees.
15
SECOND CAUSE OF ACTION

(Violation of the Utah Whistleblower’s Act Against Juab County)
64. The Utah Whistleblower Act, Utah Code Ann. § 65-21-1 et seq.,
protects public employees who communicate or object to violations of a state or
federal law, rule, or regulation. Specifically, Utah Code Ann. § 67-21-3(1)(a) states
that “[a]n employer may not take adverse action against an employee because the
employee … communicates in good faith … the waste or misuse of public funds,
property, or manpower” or “a violation or suspected violation of a law, rule, or
regulation adopted under the law of this state, a political subdivision of this state,
or any recognized entity of the United States.”
65. As more specifically set forth above, Lt. McAfee communicated his
concerns of the waste of government funds and staffing to Sheriff Anderson, Chief
Deputy Taylor, and Mr. Seely the County’s HR Director.
66. In addition, Lt. McAfee also communicated his concerns about gender
discrimination and stereotyping towards two female jail sergeants to Sheriff
Anderson and Mr. Seely.
67. Defendant Juab County took adverse action against Lt. McAfee
because of his reports. For example, as more fully set forth above, after Lt.
McAfee reported Sheriff Anderson’s misconduct and his waste of public funds and
16
staffing Sheriff Anderson and Chief Taylor criticized Lt. McAfee for not simply
following along and threatened Lt. McAfee to not oppose the Sheriff. Mr. Seely
initiated an investigation that focused on alleged wrongdoing by Lt. McAfee while
glossing over the Sheriff’s behavior and accused Lt. McAfee of misconduct and
disloyalty, and threatened his employment. In addition, Sheriff Anderson initiated
a sham investigation to discredit Lt. McAfee and to create “cause” to terminate
him. Ultimately, the County via Sheriff Anderson, terminated Lt. McAfee claiming
they “had a lot of evidence to back up the termination.”
68. Juab County’s actions constitute a violation of the Utah
Whistleblower Act and Lt. McAfee has been injured as a result of the County’s
actions.
69. Lt. McAfee is entitled to: back pay and benefits, reinstatement (or
front pay and benefits in lieu of reinstatement), and interest (both pre and post-
judgment).
70. As a further result of the County’s actions, Lt. McAfee is also entitled
to general damages due to his emotional distress and damage to his reputation, and
loss of enjoyment of life.
71. Lt. McAfee is also entitled to recover his attorney’ fees and costs
incurred in bringing this action.
THIRD CAUSE OF ACTION

(Retaliation in Violation of Title VII Against the County)
17
73. The County may not retaliate against an employee who has either
opposed any practice made unlawful under Title VII or has made a charge or
participated in any matter in an investigation of sexual harassment.
74. Lt. McAfee opposed Sheriff Anderson’s treatment of the female jail
sergeants and the corresponding gender discrimination and stereotyping by other
County employees and, in addition, reported his good faith belief of discrimination
to Mr. Seely.
75. The County took adverse action against Lt. McAfee when it pressured
him to go along with policies and actions he opposed, targeted him with an
investigation, tried to manufacture a charge of dishonesty with a second
investigation, and when it terminated his employment.
76. A causal connection exists between the adverse actions and Lt.
McAfee’s report of discrimination because the adverse actions were taken shortly
after Lt. McAfee opposed and reported discrimination.
77. Lt. McAfee has been injured as a result of the County’s actions.
78. Lt. McAfee is entitled to: back pay and benefits, reinstatement (or
front pay and benefits in lieu of reinstatement), and interest (both pre and post-
judgment).
18
79. As a further result of the County’s actions, Lt. McAfee is also entitled
to general damages due to his emotional distress and damage to his reputation, and
loss of enjoyment of life.
80. Lt. McAfee is also entitled to recover his attorney’ fees and costs
incurred in bringing this action.
REQUEST FOR JURY TRIAL
Plaintiff requests a trial by jury of any issue triable of right by jury.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests that the Court enter
judgment in his favor and against Defendants, and award the following relief:
a. Back pay and benefits, in amounts to be determined at trial, plus the
“gross up” of such award to account for income tax consequences;
b. Compensatory (emotional distress) and consequential damages;
c. Punitive damages as allowable;
d. Reinstatement and/or front pay and benefits in lieu of reinstatement;
e. Injunctive and/or declaratory relief;
f. Pre-judgment and post-judgment interest at the highest lawful rate;
g. Attorneys’ fees and costs of this action, including expert witness fees,
as appropriate; and
h. Any such further relief as justice allows.
19
DATED this 7th day of May, 2018.
STRINDBERG & SCHOLNICK, LLC
/s/ Cameron Platt

Cameron Platt
Attorney for Plaintiff
20

Juab County Lawsuit

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Case 2:18-cv-00371-DBP Document 2 Filed 05/07/18 Page 1 of 20

Cameron Platt (Bar No. 16548)

Attorneys for Plaintiff

IN THE UNITED STATES DISTRICT COURT

JUAB COUNTY, a political Civil No. 2:18-cv-00371-DBP

Plaintiff Lynn McAfee (“Plaintiff” or “Lt. McAfee”), by and through his

attorneys, hereby complains against Defendants Juab County (the “County”),

Seely”) (Collectively Defendants) as follows:

I. NATURE OF THE CLAIMS

Protection of Public Employees Act, Utah Code Ann. § 67-21 et seq.

2. Defendant Juab County is a political subdivision of the State of Utah.

3. Sheriff Doug Anderson is a citizen of the State of Utah and is the

individual capacities for all available relief.

4. Defendant Mike Seely is a citizen of the State of Utah and is the

and individual capacities for all available relief.

III. JURISDICTION AND VENUE

5. This Court has jurisdiction over this matter pursuant to 28 U.S.C. §

1331, § 1343 and § 1367.

6. Venue is proper with this Court pursuant to 28 U.S.C. § 1391(b)

because all the employment practices or individual acts alleged to be unlawful

7. On March 6, 2018, Lieutenant McAfee served Defendant Juab County

IV. GENERAL ALLEGATIONS

1. Juab County recruited and subsequently hired, Mr. McAfee on

public agency law enforcement jobs.

during this time period.

May 12, 2016 upon request by Lt. McAfee.

County Human Resource Policies.

8. Lt. McAfee successfully completed his probationary period and was a

shifts when needed.

9. Significantly, the County treated Lt. McAfee as a merit service

Jail Commanders and in calculating his pay.

a. The County employed two other lieutenants, in addition to Lt.

McAfee, that were both merit service employees.

b. The County paid Lt. McAfee overtime and compensation time,

at time and a half, as a merit service employee when non-merit service

employees are only eligible for overtime or compensation time at straight

time according to County policy.

c. The previous Jail Commander, Howard Jacquart whom Lt.

McAfee replaced, was classified as a merit service employee and received

overtime pay as such.

d. John Hunt who was Jail Commander before Howard Jacquart

was a Captain, was classified as a merit service employee, and received

overtime pay as such.

received a failing evaluation from the Utah State Department of Corrections

conduct required checks on inmates.

Standards Inspector that “things have never run better.”

12. Throughout his employment as Jail Commander, Lt. McAfee

staffing and budget available to the jail.

13. For example, Sheriff Anderson ordered Lt. McAfee to create a

6:00AM to 10:00PM, seven days a week. The implementation of such a schedule

14. Unfortunately, Sheriff Anderson failed to pass on his directive to the

supervisors of the road deputies.

15. When confronted at a patrol meeting by the road deputies, Sheriff

County and within law enforcement.

correctional officers to be Law Enforcement Officer certified (“LEO”) at Peace

hundreds of thousands of dollars including wages, per diem, and reimbursement

19. Sheriff Anderson’s decision also carried additional personnel costs.

and higher hourly pay rates.

likelihood of them leaving to other agencies upon completion of the training.

21. A few days after Sheriff Anderson’s announcement, Chief Deputy Al

about the news of sending the correctional officers through POST.

had made significant investment in costs and time.

have to always fight everything that I do?”

support your decision and be united if we want to remain in our positions.”