Three Little Rock police officers and one officer who was recently fired sued Police Chief Keith Humphrey in Pulaski County Circuit Court on Monday, alleging adverse treatment by the chief and other police personnel.
The plaintiffs -- Lt. John Michael Trent, Lt. Rusty Rothwell, Sgt. Christopher "Kirk" McCauley and former officer David Mattox -- are represented by attorney Robert Newcomb.
In addition to Humphrey, the lawsuit names the city of Little Rock, Assistant Chief Crystal Young-Haskins, Lt. Brittney Gunn and Lt. James Sloan.
The complaint largely centers on the 2020 investigation of an individual suspected of exposing himself to women in Little Rock, with an emphasis on Mattox's role within that investigation. A suspect, Ricardo Ramirez-Gonzalez, was arrested on several counts of indecent exposure on Aug. 30, 2020, police said at the time.
The complaint says Mattox's wife was jogging when an individual exposed and fondled himself in front of her. Later she was subjected to that individual again exposing himself and following her down the street in a vehicle, according to the complaint.
The lawsuit alleges that Gunn was presented with information from Mattox about the suspect's vehicle after he identified it while on patrol, but Gunn "did not take any meaningful actions to apprehend this sexual deviant thereby subjecting his behavior to" five additional women in the city.
The complaint ties Gunn and detective Aaron Mathis -- who was reportedly assigned the investigation of the individual exposing himself -- to accusations against plaintiffs McCauley and Rothwell. It says the plaintiffs believe that Gunn falsely claimed that Rothwell and McCauley pointed out the suspect's picture to Mattox's wife before she was shown a lineup.
The two officials were relieved of duty with pay but were cleared of any wrongdoing June 22, according to the complaint. McCauley and Rothwell lost off-duty employment as a result, according to the lawsuit, though what their off-duty work consisted of is unclear.
Once McCauley and Rothwell returned to work, Humphrey transferred them to the Patrol Division in retaliation and for the purpose of protecting Gunn, the lawsuit argues.
The lawsuit says then-Sgt. Trent wanted to investigative Mathis and Gunn but was prevented from doing so by Sloan. Trent, who is now a lieutenant, was transferred from the Internal Affairs division, according to the complaint.
In an investigation of Mattox in which Young-Haskins recommended termination, Humphrey concurred and wrote a memo to Sloan in which he said Mattox's case should be forwarded to the local FBI office for investigation of whether the actions of Mattox or others violated the arrestee's civil rights, according to the complaint.
The complaint also alleges that during the Internal Affairs investigation of Mattox, Young-Haskins repeatedly sent the file back to lower-ranking officers in an attempt to find Mattox in violation of rules and regulations, but the other personnel refused.
The lawsuit argues that Humphrey and Young-Haskins discriminated against the plaintiffs compared with their treatment of similarly situated Black personnel.
Humphrey "has shown a pattern of making transfers to more desirable assignments within the Police Department" in favor of Black personnel, the complaint says.
The complaint says Gunn "refers to Defendant [Young-]Haskins as mother in public and private venues." But when reached by phone Monday, Newcomb said Young-Haskins and Gunn are not related.
He suggested the reference was meant to convey that Young-Haskins has an improper role in protecting Gunn within the department.
Newcomb could not recall the date when Mattox was terminated but said it was sometime this month. He said Mattox's Civil Service Commission hearing is set for Oct. 7-8.
The complaint accuses Humphrey and the other personnel of abuse of process, racial discrimination and violation of the plaintiffs' rights under the Arkansas Constitution.
It asks the court to award punitive and compensatory damages as well as attorney's fees and court costs. Additionally, it requests that Mattox be reinstated to his position with the department's SWAT unit, among other items.
Newcomb said Mattox was one of the snipers on the SWAT team.
The lawsuit filed Monday follows recent efforts by Newcomb to obtain the results of a human resources investigation into Humphrey and the department.
They include an unsuccessful Arkansas Freedom of Information Act lawsuit in which Newcomb represented the same individuals listed as plaintiffs in the lawsuit filed Monday, as well as a separate lawsuit in which Newcomb is representing former Little Rock officer Charles Starks.
According to a July 15 memo written by Humphrey that was contained in court filings for the Starks lawsuit, the police chief wrote that he concurred with Young-Haskins' recommendation to terminate Mattox for violations of unauthorized investigation and untruthfulness.
"It is very clear that Officer Mattox clearly violated department policies by utilizing sensitive police resources to conduct an unauthorized criminal investigation involving his wife," Humphrey wrote. "I also believe that others who participated in the latter part of this criminal investigation expedited certain areas to make an arrest."
In the memo addressed to Sloan, who was listed as professional standards commander, Humphrey wrote that Mattox was untruthful during an initial interview with Internal Affairs, and he argued that the officer "should have refrained from participating in this investigation involving his spouse."
"I understand the desire to protect one's family member from harm," the police chief added. "However, it appears that the investigation was not moving to the expectation and/or satisfaction of Officer Mattox."
He wrote that the case ought to be forwarded to the FBI as well as the city's citizen police review board.
The memo from Humphrey listed the allegations of untruthfulness and unauthorized investigation as sustained, but an allegation of insubordination was listed as not sustained.
CORRECTION: The memo linked in this story is from Little Rock Police Chief Keith Humphrey and was written in July. An earlier version of this story incorrectly stated who wrote the memo and when it was written.