Salem 'Sleeping' Lawsuit

In 2004 former Salem (Ore.) police-fire dispatcher Jon R. Brown filed a lawsuit in federal District Court alleging violation of his First and Fourteenth Amendment rights. The case involved his termination, which he claimed were in retaliation for filing complaints against management, but which the city says was for sleeping on-duty, missing calls and performing personal business during work.

The following is a selection of documents filed with the court during the three-years the case was being process. All of the files in in Acrobat (pdf) format.

• the lawsuit
• city's answer to the lawsuit
• summary of the lawsuit
• Brown's affadavit
• an excerpt of Brown's deposition
• report from city expert Robert A. Male, Ph.D.
• report from city expert Eric Swanson
• report from city expert Ronald Turco, M.D.
• letter from sleep disorder doctor
• city intent to fire letter to Brown
• 1994 city correspondence letter on Brown sleeping
• 2002 written reprimand letter on Brown sleeping
• 2001 Brown e-mail on accusations of sleeping
• 2003 written reprimand letter on Brown missing calls
• deposition excerpt of Constance Munnel
• deposition excerpt of Teri White