Complaint 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22
2/18/2019 5:50 PM 19CV07520 1 2 IN THE CIRCUIT COURT OF THE STATE OF OREGON 3 FOR THE COUNTY OF MARION 4 ANNE MONTGOMERY and 19CV07520 ADRIANNA MARTIN-WYATT, Case No.: 5 6 Plaintiffs, COMPLAINT 7 v. (42 U.S.C. Section 1983 – Violations of Equal Protection – Sexual Harassment and Gender 8 STATE OF OREGON, LEGISLATIVE Discrimination; Negligence; Negligent 9 ASSEMBLY and STATE OF OREGON Supervision; Negligent Retention and LEGISLATIVE ADMINISTRATION ORS 659A.030(b) and 659A.403(1) and (3)) 10 COMMITTEE, JEFF KRUSE, PETER COURTNEY, DEXTER JOHNSON, and PRAYER: $6,700,000 11 LORE CHRISTOPHER, each in their ORS 21.160(1)(d) individual and official capacities, 12 JURY TRIAL REQUESTED 13 Defendants. (Not subject to mandatory arbitration) 14 NATURE OF THE CASE 15 1. This is an action under 42 U.S.C. § 1983 and the Fourteenth Amendment to the 16 United States Constitution, which grants individuals the right to sue government employees and 17 others acting under color of state law for civil rights violations. Plaintiffs seek money damages 18 to redress the constitutional violations that resulted from sexual harassment at the Oregon State 19 20 Capitol. This is also an action for common law claims and state statutory claims as well as for 21 declaratory and injunctive relief. 22 2. Legislative interns in Oregon have a clearly established constitutional right to 23 work at the state’s Capitol building free from sexual harassment by state legislators and staff. 24 Former Senator Jeff Kruse routinely sexually harassed women at the Capitol and created a 25 sexually hostile work environment for many years, beginning well before the time period when 26 Rohny Law 1212 SE Spokane Street Page 1 COMPLAINT Portland, OR 97202 Tel.
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