CV-2015-02-0849

CMCO

02/16/2015 18:32:41 PM

GALLAGHER, PAUL Page 1 of 5

COURT OF COMMON PLEAS

SUMMIT COUNTY, OHIO
CRYSTAL LYNNE CASTERLINE
c/o
Law Office of Nancy Grim
Nancy Grim, LLC
136 N. Water Street, Suite 202
Kent, OH 44240-2450
Plaintiff

CASE NO.

JUDGE

COMPLAINT

-vs-

With Jury Demand.

DAVID A. OLIVER, f/k/a David A. Blough

13483 Judy Ave Northwest
Uniontown, Oh 44685
Defendant
INTRODUCTION
1.

Plaintiff brings this action to redress injuries caused by the wrongful conduct of

Defendant.
2.

Plaintiff Crystal Lynne Casterline is a resident of Summit County, Ohio.

3.

Defendant David A. Oliver, f/k/a David A. Blough, is a resident of Summit

County, Ohio.
4.

Defendant was the Chief of Police of Brimfield Township, Ohio from 2004 until

he resigned on January 16, 2015.

5.

Plaintiff Casterline has been an employee of the Brimfield Township Police

Department from April 1, 2013 to the present.

6.

Plaintiff worked under the supervision of Defendant Oliver until January 16,

2015, when Defendant resigned from employment with Brimfield Township.

Daniel M. Horrigan, Summit County Clerk of Courts

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GALLAGHER, PAUL Page 2 of 5

On multiple occasions from April 1, 2013 to January 16, 2015, including multiple

occasions each week during the year immediately prior to filing this complaint, Defendant
engaged in intentional and/or reckless conduct which caused harm to Plaintiff, in violation of
Plaintiffs rights under common law and statutes, as further alleged below.
COUNT ONE: Ohio Civil Rights Act, R.C. 4112.02(J).
8.

In a continuing series of actions from April 1, 2013 to January 16, 2015,

Defendant, motivated by gender discrimination, perverted his role as chief of police to perpetrate
acts against Plaintiff which adversely affected the terms and conditions of her employment. Such
acts included, but was not limited to, sexual harassment in the form of unwanted physical
touching of a sexual nature, despite repeated statements by Plaintiff objecting to such conduct,
and verbal statements of a sexual nature, all directed to Plaintiff because of her gender.
9.

Such acts were both severe and pervasive, such that Defendant created a hostile

work environment that substantially impaired the conditions of Plaintiffs employment.

10.

In addition, Defendant engaged in a series of actions toward Plaintiff motivated by

retaliation for Plaintiffs opposition to sexual harassment. Retaliatory actions by Defendant

included, but was not limited to, physically striking Plaintiff in her throat and thigh, derogatory
statements, inventing arbitrary rules for Plaintiff,
11.

Defendant obstructed or prevented employees of the police department, including

Plaintiff, her direct supervisors and her co-workers, from making complaints to the Township
Trustees about the unlawful conduct of Defendant.
12.

Defendant obstructed or prevented the direct supervisors of Plaintiff from taking

action to protect Plaintiff from Defendants unlawful discriminatory and retaliatory conduct,
including by his refusal to allow Plaintiff to transfer to a shift which would limit Plaintiffs
contact with Defendant.
Daniel M. Horrigan, Summit County Clerk of Courts
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Such actions by Defendant Oliver constitute unlawful discriminatory practices in

violation of R.C. 4112.02(J).

14.

As a result of the unlawful discriminatory practices by Defendant Oliver, Plaintiff

has suffered medical expenses, loss of income, and other economic damages, as well as physical
injury and sickness, pain and suffering, severe emotional distress, loss of self esteem, insult,
embarrassment, fright, and other damages to be shown at trial.
15.

Defendant acted with malice and/or reckless indifference to the protected rights

of Plaintiff and others, for which Defendant is liable for punitive damages.
COUNT TWO: False Imprisonment.
16.

On multiple occasions from April 1, 2013 to January 16, 2015, including multiple

occasions each week during the year immediately prior to filing this complaint, Defendant used
actual force to restrain the physical liberty of Plaintiff, without probable cause or other right.
17.

As a result of Defendants unlawful physical restraint, Plaintiff has suffered

medical expenses, loss of income, and other economic damages, as well as physical injury and
sickness, pain and suffering, severe emotional distress, loss of self esteem, insult, embarrassment,
fright, and other damages to be shown at trial.
18.

Defendant acted with malice and/or reckless indifference to the protected rights

of Plaintiff and others, for which Defendant is liable for punitive damages.
COUNT THREE: Civil Assault.
19.

On multiple occasions from April 1, 2013 to January 16, 2015, including multiple

occasions each week during the year immediately prior to filing this complaint, Defendant
intentionally offered or attempted, without authority or consent, to harm or offensively touch
Plaintiff such that Defendant put Plaintiff in fear of actual harmful or offensive contact.

Daniel M. Horrigan, Summit County Clerk of Courts

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As a result of Defendants civil assault, Plaintiff has suffered medical expenses,

loss of income, and other economic damages, as well as physical injury and sickness, pain and
suffering, severe emotional distress, loss of self esteem, insult, embarrassment, fright, and other
damages to be shown at trial.
21.

Defendant acted with malice and/or reckless indifference to the protected rights

of Plaintiff and others, for which Defendant is liable for punitive damages.
COUNT FOUR: Battery.
22.

On multiple occasions from April 1, 2013 to January 16, 2015, including multiple

occasions each week during the year immediately prior to filing this complaint, Defendant
intentionally or recklessly touched Plaintiff in a harmful and offensive manner, without authority
and knowing that Plaintiff did not consent.
23.

As a result of Defendants battery, Plaintiff has suffered medical expenses, loss of

income, and other economic damages, as well as physical injury and sickness, pain and suffering,
severe emotional distress, loss of self esteem, insult, embarrassment, fright, and other damages to
be shown at trial.
24.

Defendant acted with malice and/or reckless indifference to the protected rights

of Plaintiff and others, for which Defendant is liable for punitive damages.
COUNT FIVE: Intentional infliction of serious emotional distress.
25.

On multiple occasions from April 1, 2013 to January 16, 2015, including multiple

occasions each week during the year immediately prior to filing this complaint, Defendant
intentionally or recklessly acted toward Plaintiff in an extreme and outrageous manner so as to
cause serious emotional distress to Plaintiff.

Daniel M. Horrigan, Summit County Clerk of Courts

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The conduct of Defendant was so outrageous in character and so extreme in

degree that it went beyond all bounds of decency and would be regarded as atrocious and utterly
intolerable in a civilized community.
27.

As a result of Defendants intentional infliction of emotional distress, Plaintiff has

suffered medical expenses, loss of income, and other economic damages, as well as physical
injury and sickness, pain and suffering, severe emotional distress, loss of self esteem, insult,
embarrassment, fright, and other damages to be shown at trial.
28.

Defendant acted with malice and/or reckless indifference to the protected rights

of Plaintiff and others, for which Defendant is liable for punitive damages.
WHEREFORE, Plaintiff Crystal L. Casterline prays that the Court order judgment for
Plaintiff on all claims, including
(a)

Compensatory damages in excess of $25,000;

(b)

Punitive Damages in excess of $25,000, as well as all reasonable attorney's fees

and costs incurred by Plaintiff;

(c)

Such other relief as the Court may deem just and equitable.

JURY DEMAND:
Plaintiff demands a trial by jury on all issues so triable.
Respectfully submitted,
s/ Nancy Grim
NANCY GRIM (0014376)
Nancy Grim LLC
136 N. Water Street, Suite 202
Kent, OH 44240-2450
330-678-6595 / Fax 844-270-7608
nancy.grim@nancygrimlaw.net
Counsel for Plaintiff
Daniel M. Horrigan, Summit County Clerk of Courts
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