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Ryan Anthony Johnson vs. Arkansas State University A Complaint in a Case of Racial Discrimination
UNITED STATES DISTRICT COURT FOR THE EASTERN DISTICT OF ARKANSAS JONESBORO DIVISION
RYAN ANTHONY JOHNSON 101 Mark Street Jonesboro, AR 72401
- Plaintiff, -against- ARKANSAS STATE UNIVERSITY, JONESBORO P.O. Box 600 State University, AR 72467 CHARLES L. WELCH, AS PRESIDENT ARKANSAS STATE UNIVERSITY SYSTEM P.O. Box 600 State University, AR 72467 TIM HUDSON, AS CHANCELLOR (FORMER) ARKANSAS STATE UNIVERSITY, JONESBORO P.O. Box 600 State University, AR 72467 LYNITA COOKSEY, AS PROVOST AND VICE CHANCELLOR, ACADEMIC AFFAIRS & RESEARCH ARKANSAS STATE UNIVERSITY, JONESBORO P.O. Box 600 State University, AR 72467
PLAINTIFF COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF AND DAMAGES FOR VIOLATIONS OF THE FIRST AND FOURTEENTH AMENDMENTS TO THE U.S. CONSTITUTION, BREACH OF CONTRACT, 42 U.S.C. ยง 1981 & RELATED CLAIMS. JURY DEMANDED CASE NO: ________________________
WILLIAM R. STRIPLING, AS VICE CHANCELLOR FOR STUDENT AFFAIRS ARKANSAS STATE UNIVERSITY, JONESBORO, P.O. Box 600 State University, AR 72467 RICHARD BURNS, INDIVIDUALLLY, AND AS A PROFESSOR ARKANSAS STATE UNIVERSITY, JONESBORO P.O. Box 600 State University, AR 72467 - Defendants.
PLAINTIFF COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF AND DAMAGES FOR VIOLATIONS OF THE FIRST AND FOURTEENTH AMENDMENTS TO THE U.S. CONSTITUTION, 42 U.S.C. ยง 1981, 42 U.S.C. ยง 1982, 42 U.S.C. ยง 1983, 42 U.S.C. ยง 1985, & 42 U.S.C. ยง 1986 BREACH OF CONTRACT & RELATED CLAIMS.
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COMES NOW the plaintiff, Ryan Anthony Johnson, as and for a Complaint against the defendants above named, states, alleges, and avers as follows: PRELIMINARY STATEMENT
1.
Plaintiff, Ryan Anthony Johnson, is an African-American, and now expelled,
student at formerly enrolled at Arkansas State University, Jonesboro. Plaintiff was wrongfully expelled by defendants because of his race, racial animus, and for his political beliefs, and his refusal to engage the defendants in a disciplinary process that violated his rights and privileges as afforded by the First Amendment to the U.S. Constitution and the Due Process Clause of the 14th Amendment to the U.S. Constitution. Defendants have intentionally, wantonly and recklessly caused severe academic, financial and emotional damage to the plaintiff by expelling him from Arkansas State University and barring him from any future enrollment at the institution or access to the institution’s facilities, programs or staff, in perpetuity. Plaintiff seeks redress for the harms caused by the defendants, subjecting plaintiff to permanent expulsion, or what amounts to capital punishment in academia, for allegations of improper etiquette at a guest speaker event, eating free and publicly offered food, and debating in a classroom.
2.
This is a civil action to recover damages for the deprivation of plaintiff’s rights or
privileges as a citizen of the United States caused by the defendants and because plaintiff chose to exercise rights afforded him under federal law and under the laws of the State of Arkansas. Plaintiff seeks compensatory damages, joint and severally, from all defendants in the amount of $4.8
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million (Four-Million-Eight-Hundred-Thousand-Dollars) and punitive damages from defendant Richard Burns in an amount to be determined at trial.
JURISDICTION AND VENUE 3.
This Court has subject matter jurisdiction over this action pursuant to (i) 28 U.S.C.
§ 1331, which confers original jurisdiction upon this Court for actions arising under the laws of
the United States; and (ii) pursuant to 28 U.S.C. §§ 1343 and 1343, which confer original jurisdiction upon this Court in a civil action to recover damages or to secure equitable relief under any Act of Congress providing for the protection of civil rights of American citizens; and (iii) under the Declaratory Judgment Statute, 28 U.S.C. § 2201. 4.
Venue is proper in this Court pursuant to 28 U.S.C. §§ 1391(b)(1) and (c), in that
the defendants maintains offices, conducts business, and resides in this judicial district, and a substantial portion of the acts that make up the basis of the Complaint occurred within this judicial district. DEMAND FOR TRIAL BY JURY 5.
Pursuant to Rule 38(b) FRCP, the plaintiff hereby demands a jury of all issues so
triable. NO IMMUNITY UNDER STATE LAW 6.
Plaintiff avers that the wrongful and illegal actions and inactions and omissions of
defendants complained of herein were practiced with actual malice and reckless disregard towards plaintiff and his legal rights and property interests, and were willful and constituted
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malicious, intentional, willful, outrageous, reckless and flagrant misconduct, so as to deprive the defendants of any immunity under Arkansas State law. Plaintiff further avers that any State law, ordinance, proclamation, regulation, statute, etc., pursuant to which defendants, claim they acted, is unconstitutional, and the defendants’ conduct pursuant to any State law, ordinance, proclamation, regulation, statute, etc., which violated plaintiff’s federally guaranteed rights cannot be immunized by State law.
NOTICE OF CLAIMS & EXHAUSTION OF ADMINISTRATIVE REMEDIES 7.
Plaintiff, at all times herein, have satisfied all requirements and conditions
precedent to this lawsuit. 8.
Furthermore, where such requirements may not have been met, plaintiff aver that
such requirements are unconstitutional and are promulgated in violation of the Due Process and Equal Protection Clauses of the 14th Amendment of the United States Constitution and the facts and circumstances from which plaintiffs’ claim arise have constituted a barrier prohibiting plaintiff from satisfying any mandated law, regulation or ordinance regarding a condition precedent to this lawsuit. PARTIES
9.
Plaintiff, at all times herein, is a U.S. citizen, a resident of the City of Jonesboro,
County of Craighead, State of Arkansas.
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10.
Plaintiff is an African-American male, over the age of 18, and a former student of
Arkansas State University at Jonesboro.
11.
At the time of first matriculation at defendant Arkansas State University, Plaintiff
had obtained and earned a Bachelor of Science Degree and was attempting to complete a graduate/post secondary degree.
12.
Defendant Arkansas State University at Jonesboro is a (hereinafter “ASU“) state
chartered and state funded institution of higher education of the State of Arkansas, and a regional campus of the Arkansas State University System.
13.
Defendant ASU is located in the City of Jonesboro, County of Craighead, State of
Arkansas.
14.
Defendant Charles L. Welch, is the President of the Arkansas State University
System and is responsible for the policies and practices of defendant ASU.
15.
Defendant Tim Hudson, is the former Chancellor of defendant ASU, acting as chief
administrative officer of defendant ASU at the time plaintiff matriculated at ASU.
16.
Defendant Lynita Cooksey is the Provost and Vice Chancellor for Academic Affairs
and Research at defendant ASU.
17.
Upon information and belief, defendant Lynita Cooksey is also the acting
Chancellor at defendant ASU, replacing former ASU Chancellor defendant Tim Hudson on or about August 2016.
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18.
Defendant William R. Stripley is the Vice Chancellor For Student Affairs of
defendant ASU, with oversight responsibiities of student affairs, including student disciplinary hearings.
19.
Defendant Richard Burns, is being sued in his individual capacity as well as his
capacity as employee/professor at defendant ASU. 20.
Defendant Richard Burns is a former instructor of the plaintiff. STATEMENT OF RELEVANT FACTS
21.
Plaintiff first enrolled at defendant ASU for the Spring semester of the 2010 - 11
academic year and remained enrolled, except for his voluntary time off for financial reasons, until he was expelled from defendant ASU on May 2, 2014.
22.
Plaintiff first enrollment was in a graduate program leading to a Master’s Degree
in Education, matriculating on a part time basis.
23.
Plaintiff, as a matriculating student at defendant ASU, agreed to be bound by
university rules and regulations, including promulgated rules governing student conduct.
24.
Plaintiff was properly enrolled and attended defendant ASU from the Spring
Semester of 2011 and up to the Spring Semester of 2014, without any allegations of violations of defendant ASU’s Student Code of Conduct.
25.
On February 11, 2014, during the Spring Semester of the 2013-14 academic year,
plaintiff was attending a public event on the campus of defendant ASU, where plaintiff sought to
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speak directly with the guest speaker. Plaintiff was informed that he could not speak directly with the guest speaker and left the event without engaging in any misconduct. 26.
On February 19, 2014, during the Spring Semester of the 2013-14 academic year,
plaintiff was attending a public function at the Multi-Cultural Center on the campus of defendant ASU, where free food was publicly offered, on display, and made available to attendees on a selfserve basis. Plaintff arrived at the scheduled function after the main event, prepared a plate of food, and was reprimanded for being in attendance at the event for the sole purpose of obtaining the free food. University police detained plaintiff, verified that plaintiff was a student and released plaintiff. Plaintiff was not allowed to keep the plate of food that he prepared for himself. 27.
On April 24, 2014, during the Spring Semester of the 2013-14, plaintiff enrolled in
undergraduate course taught by defendant Richard Burns. The course was titled “AfricanAmerican Folklore� and provided for vigorous debate about African-American history and traditions. Plaintiff debated, objected to, and disagreed with academic positions taken by the professor and other students, all the while maintain proper decorum.
28.
On April 25, 2014, plaintiff was informed by e-mail that he faced disciplinary
charges at defendant ASU arising out his conduct on February 19, 2014 and April 24, 2014.
29.
On April 25, 2014, plaintiff was informed by e-mail that he should have no contact
with any faculty or staff at defendant ASU, except for a Vice Chancellor or a Assistant Dean of Students, until after a meeting that was scheduled for April 29, 2014, all because of his conduct on February 19, 2014 and April 24, 2014.
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30.
On April 25, 2014, plaintiff was informed by e-mail that he would be subject to
arrest if he appeared on campus because of his conduct on February 19, 2014 and April 2, 2014.
31.
On April 25, 2014, plaintiff was informed by e-mail that a meeting was scheduled
with him for April 29, 2014 to address the charges lodged against him because of his conduct on February 19, 2014 and April 24, 2014.
32.
April 25, 2014 was on a Friday and April 29, 2014 was the following Tuesday.
33.
On or about April 26, 2014, plaintiff learned of the university actions of April 25,
2014 and sought to inform two of his professors, by e-mail, that he could not complete pending class assignments until the disciplinary matter was concluded.
34.
On Monday April 28, 2014 plaintiff sought an adjournment of the April 29, 2014
meeting to obtain legal counsel and gather evidence.
35.
Plaintiff request to delay the April 29, 2014 meeting was denied and he was
informed that he could not have legal counsel or an advisor or an advocate attend the April 29, 2014 meeting scheduled by defendant ASU.
36.
Plaintiff did not attend the April 29, 2014 meeting.
37.
Defendant scheduled, for May 2, 2014, an expulsion hearing to determine
whether or not plaintiff will continue as a student or be expelled and permanently barred from defendant ASU. Plaintiff was noticed about the May 2, 2014 expulsion hearing on April 30, 2014 by e-mail.
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38.
As of May 2, 2014, in addition to the original charges of violating codes of
conduct, plaintiff was facing new charges of contacting university faculty and staff on or about April 26, 2014.
39.
As of May 2, 2014, in addition to the original charges of violating codes of
conduct and the new charges of contacting university faculty and staff on or about April 26, 2014, plaintiff faced an additional new charge of misconduct for failing to attend the scheduled April 29, 2014 meeting.
40.
Citing, lack of notice and the defendants prohibition against plaintiff being
represented by legal counsel at such hearing, plaintiff did not attend the May 2, 2014 expulsion hearing.
41.
On May 2, 2014 defendants expelled plaintiff from defendant ASU, terminating
his matriculation, permanently barring him from campus, participating in any future univerity activity or any future enrollment.
42.
The May 2, 2014 expulsion decision was affirmed by defendant Tim Hudson.
43.
Plaintiff has no adequate remedy at law for the intentional, malicious, reckless,
and grossly negligent conduct of defendants complained of herein.
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COUNT I AS AND FOR A FIRST CAUSE OF ACTION AGAINST ALL DEFENDANTS FOR THE DEPRIVATION OF PLAINTIFF’S CIVIL RIGHTS AS GUARANTEED BY FIRST AMENDMENT OF THE UNITED STATES CONSTITUTION
44.
VIOLATION OF RIGHT TO FREE SPEECH Plaintiff repeats and re-alleges each of the above paragraphs as if fully set forth
herewith. 45.
Plaintiff, acting within well established constitutional rights, on April 24, 2014,
while participating in academic debate, defendants imposed a time, place and manner restriction on plaintiff’s speech, causing an infringment of his rights based on the content of plaintiff’s speech. 46.
Defendants, acting jointly and severally, conspired to and did adversely impact
plaintiff’s enrollment, academic record, employment, employment opportunities, promotional opportunities, and past and future wages because of plaintiff’s race and in retaliation for plaintiff exercising his rights under federal and state constitutional laws, differently, disparately and wrongfully from their treatment of similarly situated white students of defendant ASU. 47.
Defendants have and did deprived plaintiff of his rights to speak freely, to make
and enforce contracts and to the full and equal benefit of defendants’ rules, regulations, laws and proceedings for the matriculation of students, administrative proceeding, grievance
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procedures, and security of plaintiff’s matriculation in violation of the First Amendment of the U.S. Constitution. 48.
Defendants knew or should have known that their conduct violated plaintiff’s
clearly established constitutional right to free speech and be free of disparate treatment because of her race. 49.
Defendants acted with intent to violate plaintiff’s clearly established rights
afforded under the First Amendments to the United States Constitution, acting in concert, and under color of law. 50.
Defendants, acting under color of law, did knowingly, intentionally, maliciously,
recklessly and wantonly deprive plaintiff of his right to free speech and to be free of disparate treatment because of his race. 51.
As of direct result of the foregoing deprivation plaintiff has suffered severe
injuries, loss past and future wages, other actual damages, along with attorney fees and costs in amount totaling $4,800,000 (Four-Million-Eight-Hundred-Thousand Dollars). COUNT II AS AND FOR A SECOND CAUSE OF ACTION AGAINST ALL DEFENDANTS FOR THE DEPRIVATION OF PLAINTIFF’S CIVIL RIGHTS AS GUARANTEED BY DUE PROCESS CLAUSE OF THE 14th AMENDMENT OF THE UNITED STATES CONSTITUTION VIOLATION OF DUE PROCESS
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52.
Plaintiff repeats and re-alleges each of the above paragraphs as if fully set forth
herewith. 53.
Plaintiff, acting within well established constitutional rights, on April 29, 2014,
plaintiff refused to participate in or engage defendants in an adminstrative process that did not afford him adequate notice, benefit of legal counsel or clearly defined charges or allegations against him. 54.
Defendants, acting jointly and severally, conspired to and did adversely impact
plaintiff’s enrollment, academic record, employment, employment opportunities, promotional opportunities, and past and future wages because of plaintiff’s race and in retaliation for plaintiff exercising his rights under federal and state constitutional laws, differently, disparately and wrongfully from their treatment of similarly situated white students of defendant ASU. 55.
Defendants have and did deprived plaintiff of his right to due process, to make
and enforce contracts and to the full and equal benefit of defendants’ rules, regulations, laws and proceedings for the matriculation of students, administrative proceeding, grievance procedures, and security of plaintiff’s matriculation in violation of the Due Process Clause of the 14th Amendment of the U.S. Constitution. 56.
Defendants knew or should have known that their conduct violated plaintiff’s
clearly established constitutional right to due process and be free of disparate treatment because of his race.
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57.
Defendants acted with intent to violate plaintiff’s clearly established rights
afforded under the Due Process Clause of the 14th Amendment to the United States Constitution, acting in concert, and under color of law. 58.
Defendants, acting under color of law, did knowingly, intentionally, maliciously,
recklessly and wantonly deprive plaintiff of his right to due process and to be free of disparate treatment because of his race. 59.
As of direct result of the foregoing deprivation plaintiff has suffered severe
injuries, loss past and future wages, other actual damages, along with attorney fees and costs in amount totaling $4,800,000 (Four-Million-Eight-Hundred-Thousand Dollars).
COUNT III AS AND FOR A THIRD CAUSE OF ACTION AGAINST ALL DEFENDANTS FOR THE DEPRIVATION OF PLAINTIFF’S CIVIL RIGHTS AS GUARANTEED BY 42 U.S.C. § 1981 RACE DISCRIMINATION 60.
Plaintiff repeats and re-alleges each of the above paragraphs as if fully set forth
herewith. 61.
Defendants, acting jointly and severally, conspired to and did adversely impact
plaintiff’s matriculation, academic record, employment, employment opportunities, promotional opportunities, and past and future wages because of plaintiff’s race and in retaliation for plaintiff exercising his rights under federal and state constitutional laws, differently, disparately and wrongfully from their treatment of similarly situated white students of defendant ASU.
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62.
Defendants have and did deprive plaintiff of his rights to make and enforce
contracts and to the full and equal benefit of defendants’ rules, regulations, laws and proceedings for the enrollment, discipline, administrative proceeding, grievance procedures, and security of plaintiff’s status as student because of plaintiff’s race in violation of 42 U.S.C. §1981. 63.
Defendants knew or should have known that their conduct violated plaintiff’s
clearly established constitutional rights and be free of disparate treatment because of his race. 64.
Defendants acted with intent to violate plaintiff’s clearly established rights
afforded under the First and Fourteen Amendments to the United States Constitution, acting in concert and under color of law. 65.
Defendants, acting under color of law, did knowingly, intentionally, maliciously,
recklessly and wantonly deprive plaintiff of his right to be free racial animus and disparate treatment because of his race. 66.
As of direct result of the foregoing deprivation plaintiff has suffered severe
injuries, loss past and future wages, other actual damages, along with attorney fees and costs in amount totaling $4,800,000 (Four-Million-Eight-Hundred-Thousand Dollars).
COUNT IV AS AND FOR A FOURTH CAUSE OF ACTION AGAINST ALL DEFENDANTS FOR THE DEPRIVATION OF PLAINTIFF’S CIVIL RIGHTS AS GUARANTEED BY 42 U.S.C. § 1982
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67.
Plaintiff repeats and re-alleges each of the above paragraphs as if fully set forth
herewith. 68.
Defendants, acting jointly and severally, conspired to and did adversely impact
plaintiff’s enrollment, academic record, employment, employment opportunities, promotional opportunities, and past and future wages because of plaintiff’s race and in retaliation for plaintiff exercising his rights under federal and state constitutional laws. 69.
Defendants have and did deprived plaintiff of his rights to make and enforce
contracts and to the full and equal benefit of defendants’ rules, regulations, and laws and proceedings for the security of plaintiff’s matriculation at defendant ASU because of plaintiff’s race and in violation of 42 U.S.C. §1982. 70.
Defendants knew or should have known that their intentional conduct violated
plaintiff’s clearly established constitutional rights to make and enforce contracts. 71.
Defendants acted with intent to violate plaintiff’s clearly established First and
Fourteen Amendment rights, acting in concert and under color of law. 72.
Defendants, acting jointly and severally, conspired to and did adversely impact
plaintiff’s enrollmen, academic recordm, employment, employment opportunities, promotional opportunities, and past and future wages because of plaintiff’s race and in retaliation for plaintiff exercising his rights under federal and state laws all in violation of 42 U.S.C. §1982.
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73.
As of direct result of the foregoing deprivation plaintiff has suffered severe
injuries, loss past and future wages, other actual damages, along with attorney fees and costs in amount totaling $4,800,000 (Four-Million-Eight-Hundred-Thousand Dollars).
COUNT V AS AND FOR A FIFTH CAUSE OF ACTION AGAINST ALL DEFENDANTS FOR THE DEPRIVATION OF PLAINTIFF’S CIVIL RIGHTS AS GUARANTEED BY 42 U.S.C. § 1983 74.
Plaintiff repeats and re-alleges each of the above paragraphs as if fully set forth
herewith. 75.
Defendants, acting jointly and severally, conspired to and did adversely impact
plaintiff’s employment, employment opportunities, promotional opportunities, and past and future wages because of plaintiff’s race and in retaliation for plaintiff exercising his rights under federal and state constitutional laws, all in violation of 42 U.S.C. § 1983. 76.
As of direct result of the foregoing deprivation plaintiff has suffered severe
injuries, loss past and future wages, other actual damages, along with attorney fees and costs in amount totaling $4,800,000 (Four-Million-Eight-Hundred-Thousand Dollars).
COUNT VI AS AND FOR A SIXTH CAUSE OF ACTION AGAINST ALL DEFENDANTS FOR THE DEPRIVATION OF PLAINTIFF’S CIVIL RIGHTS AS GUARANTEED BY 42 U.S.C. § 1985
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77.
Plaintiff repeats and re-alleges each of the above paragraphs as if fully set forth
herewith. 78.
Defendants, acting jointly and severally, knowing and intentionally, agreed and
conspired to adversely impact plaintiff’s enrollment, academic record, professional affiliations, employment, employment opportunities, promotional opportunities, and past and future wages because of plaintiff’s race and while undertaking retaliatory actions against plaintiff because he exercised his rights under federal and state constitutional laws, all with an objective to deprive plaintiff his constitutional rights. 79.
At all times herein, private individuals, or a non-government agency that are not
state officials, did act under color of state law when it agreed to and then engaged in a conspiracy with defendants to deprive plaintiff of his right to equal protection of the law and other rights afforded under the constitution of the United States when defendants wrongfully, maliciously and intentionally deprived plaintiff of his right to free speech and right to due process in comparison to similarly situated white students, white employees and white staff of defendant ASU. 80.
Defendants have an animus, dislike, hatred and bias against plaintiff and all
African-Americans, with a history of preference for white students, faculty and staff. 81.
Defendants knew, or should have known, that plaintiff is African-American and
have spoken publicly on behalf of the interests, rights and issues of concern to African-Americans.
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82.
Defendants did harass, suspend and subsequently expell plaintiff and because of
their reckless, malicious and wonton conspiracy caused irreparable financial, emotional and psychological harm as well as loss of reputation in the local community. 83.
Defendants have and did deprived plaintiff of his rights to make and enforce
contracts and to the full and equal benefit of the equal protect of the laws and to equal privilege and immunities under the laws because of plaintiff’s race in violation of 42 U.S.C. §1985. 84.
As of direct result of the foregoing deprivation plaintiff has suffered severe
injuries, loss past and future wages, other actual damages, along with attorney fees and costs in amount totaling $4,800,000 (Four-Million-Eight-Hundred-Thousand Dollars). COUNT VII AS AND FOR A SEVENTH CAUSE OF ACTION AGAINST FOR THE DEPRIVATION OF PLAINTIFF’S CIVIL RIGHTS AS GUARANTEED BY 42 U.S.C. § 1986 85.
Plaintiff repeats and re-alleges each of the above paragraphs as if fully set forth
herewith. 86.
The defendants had the actual knowledge that the wrongs complained of herein
by the plaintiff were about to happen and did actually happen and had the power and authority to prevent and stop such wrongs, or aid in the preventing or stopping such wrongs, but intentionally or neglected or refused to do so. 87.
Defendants, wantonly, maliciously, recklessly and with invidious racial animus,
acting jointly and severally, conspired to and did adversely impact plaintiff’s enrollment,
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employment, employment opportunities, promotional opportunities, and past and future wages because of plaintiff’s race and in retaliation for plaintiff exercising his rights under federal and state constitutional laws. 88.
Defendants have and did deprived plaintiff of his rights to make and enforce
contracts and to the full and equal benefit of defendants’ rules, regulations, and laws and proceedings for the hire and security of plaintiff’s employment because of plaintiff’s race and in violation of 42 U.S.C. § §1981, 1982 and 1985. 89.
As of direct result of the foregoing deprivation plaintiff has suffered severe
injuries, loss past and future wages, other actual damages, along with attorney fees and costs in amount totaling $4,800,000 (Four-Million-Eight-Hundred-Thousand Dollars).
90.
COUNT VIII AS AND FOR A EIGHTH CAUSE OF ACTION AGAINST ALL DEFENDANTS FOR BREACH OF CONTRACT Plaintiff repeats and re-alleges each of the above paragraphs as if fully set forth
herewith. 91.
Plaintiff entered into a contract with defendants for educational services.
92.
Defendants’ breached such contract upon the expulsion of plaintiff from
defendant ASU, without just cause, without notice and in reckless disregard for the terms and conditions of the contract entered into with plaintiff.
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93.
As a proximate cause of defendants’ breach, plaintiff has suffered and will
continue to suffer severe damages. 94.
As of direct result of the foregoing deprivation plaintiff has suffered severe
injuries, loss past and future wages, other actual damages, along with attorney fees and costs in amount totaling $4,800,000 (Four-Million-Eight-Hundred-Thousand Dollars).
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PRAYER FOR RELIEF WHEREFORE, plaintiff demands judgment against the defendants as follows: (a) that this Court assume jurisdiction of this matter; (b) issue and Order finding defendants in violation of all allegations in each and ever Count of this Complaint; (c) issue a declaratory judgment finding defendants’ expulsion of plaintiff from Arkansas State University was illegal and unconstitutional; (d) issue an Order requiring defendants to remove any and all adverse letters, notes, or memos from plaintiff’s student records or files under their custody and control; (e) award plaintiff compensatory damages in the amount of $4,800,000 (FourMillion-Eight-Hundred-Thousant-Dollars); (f) hold all defendants joint and severally liable for compensatory damages awarded to plaintiff, and in so lido for such damages; (g) award plaintiff punitive damages against defendant Richard Burns; (h) grant an Order restraining defendants from any retaliation in any form against plaintiff for participation in this litigation; (i) retain jurisdiction of this action until defendants have fully complied with all Orders of the Court; (j) appoint counsel to represent class action plaintiffs;
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(k) award plaintiff attorney fees and costs; (l) make further Orders as the Court deem just, necessary and proper. Dated: April 27, 2017 Jonesboro, Arkansas
Respectfully Submitted, /s/ Ryan Anthony Johnson __________________________________ Ryan Anthony Johnson Plaintiff, Pro Se 101 Mark Street Jonesboro, AR 72401-8813 (870) 275-6966 E-Mail: rjohnsonblack@gmail.com
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