Systemic Failures at NYPD Cited in New Filing Detailing Pattern of Supervisory Abuse and Institutional Indifference

New York, NY – June 27, 2025 — In a stunning and deeply disturbing development, NYPD Detective Shatorra Foster has filed a Verified Answer With Counterclaims against Plaintiff/Counterclaim-Defendant Trevlyn Headley and the City of New York, detailing a prolonged campaign of unwanted sexual conduct, psychological coercion, and professional retaliation committed by a supervisory officer within the NYPD. The claims span violations of the New York State Human Rights Law (NYSHRL), New York City Human Rights Law (NYCHRL), and the Gender-Motivated Violence Act (GMVA), and paint a harrowing picture of power-based abuse sustained and sanctioned within the department.

The allegations—spanning from September 2023 through November 2024—include graphic and detailed accounts of repeated nonconsensual oral sex, coercive sexual remarks, retaliatory threats, and a particularly egregious March 14, 2024 incident in which Headley, on duty and in uniform, allegedly forced oral sex upon Foster inside a dormitory at NYPD Headquarters.

The counterclaims allege a sustained course of coercive and nonconsensual sexual conduct—including the March 14, 2024, dormitory assault—that collectively qualifies as criminal sexual acts under New York Penal Law §§ 130.05 and 130.50. This pattern of abuse forms the basis for a gender-motivated violence claim under the New York City Gender-Motivated Violence Act (GMVA).

According to the filing:

“The oral sex committed on March 14, 2024, while Foster was isolated in a secured dormitory, was committed without consent, through abuse of authority and psychological coercion, and qualifies as criminal sexual conduct… These actions meet the definition of a gender-motivated act of violence under the GMVA.”

A Broader Pattern of Sexual Misconduct and Institutional Indifference Within the NYPD

The allegations set forth by Foster are not isolated. Rather, they reflect a longstanding and deeply entrenched pattern of sexual harassment, coercion, and institutional neglect within the New York City Police Department. Over the past decade, multiple female officers and employees have come forward with credible claims of sexual misconduct by supervisory personnel—claims that, disturbingly, mirror the power abuses, psychological coercion, and retaliatory cover-ups alleged here.

In the instant matter, Foster alleges not only a sustained course of coerced sexual conduct by Headley, but also that the misconduct was part of a broader, well-known pattern. The counterclaims further allege that Headley has a long-documented history of sexually inappropriate, coercive, and retaliatory conduct toward other female officers, both within and outside the workplace. Despite this, the NYPD’s Office of Equity and Inclusion and Internal Affairs Bureau failed to take corrective or preventive action, thereby demonstrating, as the pleading characterizes, deliberate indifference or reckless disregard for the rights and safety of subordinate officers.

“Upon information and belief, supervisory personnel and internal oversight bodies within the NYPD—including the Office of Equity and Inclusion and Internal Affairs Bureau—were aware, or should have been aware, of Plaintiff/Counterclaim-Defendant TREVLYN HEADLEY’s longstanding pattern of sexually inappropriate, coercive, and retaliatory conduct toward other female officers, both within and outside the workplace,” the Verified Answer and Counterclaims state.

While Foster is the first to publicize claims against Headley formally, the suit alludes to a known internal pattern of abuse. According to the pleading, internal whispers and informal complaints suggest Headley has exhibited a pattern of predatory behavior targeting younger female subordinates, often concealed beneath a performative façade of mentorship or professional concern. The suit alleges that Headley exploited her rank, the chain-of-command hierarchy, and the NYPD’s protected culture of silence to identify, manipulate, and dominate vulnerable female officers. Her conduct, the filing contends, was further enabled by the Department’s failure to intervene, investigate, or discipline her, even after being placed on notice of her misconduct.

Foster’s allegations are consistent with a growing number of publicized cases in which women within the NYPD have reported similar patterns of sexual harassment and institutional betrayal. For example, in Captain Gabrielle Walls v. City of New York, the plaintiff alleged pervasive harassment and retaliation after disclosing misconduct by senior officials. Shemalisca Vasquez, Ann Cardenas, and Angelique Olaechea all raised comparable claims—each involving unwanted sexual advances, systemic minimization of complaints, and retaliatory transfers or disciplinary threats. In perhaps the most high-profile case to date, Retired Lieutenant Quathisha Epps filed a December 2024 EEOC charge alleging quid pro quo harassment by former NYPD Chief of Department Jeffrey B. Maddrey. Following her disclosures, Epps was subjected to fabricated charges, unauthorized surveillance, and other related actions, including the revocation of her law enforcement certification and the unauthorized clawback of lawfully earned overtime monies.

Taken together, these cases reveal an institutional culture within the NYPD that protects harassers, punishes survivors, and fosters impunity at the highest levels of command. Despite years of litigation, public audits, and internal reviews—including the Equal Employment Practices Commission’s 2020 report highlighting systemic deficiencies in NYPD’s EEO response mechanisms—meaningful structural reform remains elusive.

In this context, Foster’s counterclaims are not merely personal; they are also substantive. They are emblematic of a broader culture of unaccountability within the Department, where power is routinely abused, sexual misconduct is normalized, and internal systems are weaponized against those who speak out. Her legal action seeks not only individual redress but a long-overdue reckoning with the institutional forces that allowed Headley’s conduct to flourish.

Retaliation After Withdrawal

The counterclaims further detail a campaign of retaliation following Foster’s attempts to withdraw from the unwanted relationship. Headley allegedly orchestrated false disciplinary charges against Foster, resulting in public humiliation, professional damage, and emotional trauma. The City of New York is named as a defendant based on claims that it failed to investigate or intervene, and instead ratified the retaliation by sustaining the fabricated charges.

Legal Claims and Relief Sought

Foster seeks redress under the New York State Human Rights Law (NYSHRL) and the New York City Human Rights Law (NYCHRL) for sexual harassment, the creation of a hostile work environment, and unlawful retaliation. Her Verified Answer and Counterclaims detail a sustained course of coercive, degrading, and nonconsensual sexual conduct initiated by her supervisor, Headley, between October 2023 and June 2024. The alleged conduct includes repeated instances of unwanted oral sex, coercive threats, possessive and sexually explicit language, and the abuse of supervisory power to control and isolate Foster.

Foster alleges that this pattern of abuse culminated in a violent sexual assault on March 14, 2024, inside a secured NYPD dormitory at One Police Plaza while Headley was on duty and in uniform. This incident, among others, constitutes a criminal sexual act under New York Penal Law §§ 130.05 and 130.50 and part of the pattern of behavior constituting the basis of a gender-motivated violence claim under the New York City Gender-Motivated Violence Act (GMVA). Foster further alleges that after withdrawing from the coerced sexual relationship, she was subjected to retaliatory acts, including formal disciplinary charges that the City of New York knowingly pursued in disregard of the documented misconduct by Headley.

Accordingly, Foster seeks compensatory and punitive damages, injunctive relief, attorneys’ fees and costs, and all other relief the Court deems proper. Her claims demand accountability not only from Headley as an individual wrongdoer, but also from the City of New York for its institutional complicity and ratification of the unlawful conduct.

Statement from Counsel

Eric Sanders, Esq., of ¸ŁŔűź§., who represents Foster, stated:

“This case is not just about one supervisor’s abusive conduct. It’s about an entire system that fails to protect the most vulnerable within its ranks. No one should endure sexual coercion or retaliation under the badge of public service. The NYPD and the City of New York must be held accountable not just for what they did—but what they failed to stop.”

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Fighting for Justice and Reform to Promote Equal Opportunity

Led by Eric Sanders, Esq., ¸ŁŔűź§. has a proven track record in civil rights litigation, representing clients in complex cases involving law enforcement misconduct and employment discrimination. Mr. Sanders, a former police officer, leverages deep insight into systemic issues facing law enforcement agencies. The firm has successfully recovered millions in damages and remains committed to promoting fairness, integrity, and meaningful reform within public institutions.

Contact: Eric Sanders, Esq.
President and Owner, ¸ŁŔűź§.
30 Wall Street, 8th Floor
New York, NY 10005
Phone: (212) 652-2782

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Read the Verified Answer With Counterclaims 

The post “You and I Don’t Have a Relationship—Your P***y and I Do”: Explosive Sexual Misconduct Allegations Rock NYPD first appeared on ¸ŁŔűź§..

Despite passing all exams and meeting every standard for graduation, NYPD recruit Emilio Andino remains in career limbo after his aunt, Lieutenant Quathisha Epps, filed a sexual harassment complaint against former Chief of Department Jeffrey B. Maddrey. The amended complaint reveals fabricated charges, racially biased drug testing, and institutional hypocrisy reaching the highest levels of NYPD leadership.

NEW YORK, NY — May 19, 2025 — New York Civil rights attorney Eric Sanders, Esq. of ¸ŁŔűź§. has filed an Amended Verified Complaint in Emilio Andino v. City of New York, et al., asserting a detailed pattern of retaliation, racial and gender-based discrimination, and constructive discharge orchestrated by NYPD officials against a Black Police Academy recruit—not for what he did, but for who he’s related to.

At the center of the case is Mr. Emilio Andino, a high-performing recruit assigned to Hook Company 24-56 at the NYPD Police Academy, whose aunt, retired Lieutenant Quathisha Epps, filed an EEOC Charge of Discrimination on December 21, 2024. The charge publicly accused then–Chief of Department Jeffrey B. Maddrey of quid pro quo sexual harassment and systemic misconduct.

Within days, the NYPD allegedly began isolating and targeting Andino, culminating in a retaliatory suspension, fabricated disciplinary charge, racially discriminatory drug test, and career obstruction, despite Andino scoring a 93 on his final trimester exam and meeting all graduation and certification requirements.

“This is not discipline. This is retaliation by association,” said Eric Sanders, Esq. “And the NYPD is using it to enforce silence across the department.”

“Different Commissioner, Same Result”: The Adams Administration’s Failure to Confront NYPD Retaliation

According to the amended complaint, Andino’s persecution occurred under four police commissioners—all appointed by Mayor Eric Adams:

• Keechant Sewell (2022–2023), who took no public or internal action despite knowledge of growing tension between Maddrey and whistleblowers.

• Edward A. Caban (July–Sept. 2024), whose short tenure was marked by continued internal deference to command loyalty.

• Thomas G. Donlon (Sept.–Nov. 2024), a former FBI official who, according to the complaint, presided over a dramatic escalation of retaliation inside the Academy, failed to launch any internal reviews or corrective measures.

• Jessica S. Tisch (appointed Nov. 2024), under whose leadership Andino was formally charged, drug tested without cause, blocked from graduation, and effectively abandoned in institutional limbo.

“Andino’s case shows what happens when leadership becomes a revolving door, but the machinery of retaliation never stops turning,” Sanders said. “Sewell ignored it. Caban enabled it. Donlon was compromised. Tisch refused to act. And through it all, Mayor Adams stood at the helm, watching his department punish the innocent.”

Racial Slurs, Sexualized Taunts, and a Staged Confrontation

The complaint describes a racially hostile and sexually charged atmosphere inside Hook Company 24-56. Fellow recruit Bahrons Asliev, who is Asian, allegedly directed racial slurs at Andino and made explicit remarks involving Andino’s 12-year-old son.

On April 1, 2025, Asliev provoked a staged confrontation after a training scenario. Despite multiple witnesses, the NYPD failed to discipline Asliev and suspended Andino without pay.

Fabricated Charges and Scientifically Discredited Drug Testing

On May 9, 2025, Andino was formally charged under Department Advocate’s Office Serial No. C-033577, authored by Inspector Angel L. Figueroa and endorsed by Chief of Training Martine N. Materasso. The justification relied on a UF49 written by Deputy Inspector Arsenio Camilo, which allegedly omitted key details, excluded exculpatory witnesses (VERAS, BATISTA, SUAREZ), and distorted events.

Days earlier, on May 5, 2025, Andino was ordered to undergo radioimmunoassay of hair (RIAH) testing—a discredited methodology known to affect Black officers disproportionately. The complaint alleges that the test was neither random nor based on probable cause and was used solely as a retaliatory mechanism.

Despite the humiliation, Andino passed the test.

Top Exam Score, Still Blocked from Graduation

On May 15, 2025, Andino scored a 93 on his third and final trimester exam—one of the highest in his class. By May 16, he had fulfilled all graduation and certification requirements.

Still, the NYPD refused to:

• Graduate him,

• Assign him to a field command,

• Provide any explanation for his stalled progression.

The complaint asserts that Andino remains technically employed, but without status, advancement, or assignment—a form of constructive discharge by design.

Materasso and the Mob: Criminal Association, No Accountability

On May 14, 2025, two days before Andino learned of his exam score, Materasso was publicly photographed at Sobro Garden in the Bronx, socializing with Jimmy “Jamie” Rodriguez, an alleged associate of the Lucchese crime family.

The image was:

• Posted on Instagram under the handle @iamjimmyrodriguez,

• Time-stamped,

• Geotagged to Sobro Garden, 26 Bruckner Boulevard in the Bronx.

The amended complaint cites statements from John Pennisi, a former Lucchese member turned government witness, who publicly identified Rodriguez as a Lucchese affiliate seeking formal induction.

Despite this clear violation of NYPD Administrative Guide 304-06(8)(c), a vaguely worded “criminal association” policy that prohibits officers from “knowingly associating” with individuals “reasonably believed” to be engaged in criminal activity, no action was taken against Materasso.

“While a Black recruit is drug tested and blocked from graduating, a white chief photographed with an alleged mob associate faces no consequences,” Sanders said. “That’s not discipline. That’s institutional hypocrisy.”

Maddrey’s Central Role and Pattern of Abuse

The complaint reserves particular condemnation for Maddrey, who retired in December 2024, just days after Epps’s complaint was filed and her story appeared in the press.

As Chief of Department, Maddrey:

• Exercised ultimate control over training, discipline, and internal affairs.

• Was directly aware of Epps’s allegations and their potential retaliation fallout.

• Took no steps to prevent or mitigate foreseeable harm to her family.

The lawsuit characterizes Maddrey’s inaction as “a tacit endorsement of reprisal.”

It also highlights Maddrey’s history of misconduct, including:

• A 2017 internal guilty plea for obstructing an investigation into an inappropriate sexual relationship with a subordinate.

• Substantiated CCRB findings from multiple use-of-force complaints.

• Recent lawsuits, including claims from Captain Gabrielle Walls and advocate Dana Rachlin, have alleged sexual harassment coverups, retaliation, and internal corruption.

Command-Level Ratification by Tisch and Kinsella

Tisch and First Deputy Commissioner Tania I. Kinsella are named for ratifying the retaliatory conduct under their authority as final policymakers under N.Y.C. Administrative Code § 14-115.

The complaint alleges they:

• Had actual knowledge of the retaliation,

• Took no corrective action,

• Perpetuated a disciplinary structure that punishes association with whistleblowers.

Legal Claims and Relief Sought

The Amended Verified Complaint asserts violations of the:

• New York State Human Rights Law (NYSHRL), and

• New York City Human Rights Law (NYCHRL)

…including claims for:

• Race and gender discrimination

• Hostile work environment

• Retaliation and constructive discharge

Plaintiff seeks:

• Compensatory and punitive damages

• Declaratory judgment

• Attorneys’ fees and costs

• Graduation and reinstatement with a field assignment

Statement from Eric Sanders, Esq.

“Institutional retaliation doesn’t always look like a demotion or a firing. Sometimes it’s quieter—a suspension, a bogus charge, a racially biased drug test, or simply stalling someone’s career until they give up. That’s what happened here. What’s more disturbing is that while they were punishing Emilio Andino for who he’s related to, they were protecting executives fraternizing with reputed mob figures. The public should know this is how the NYPD operates behind the curtain.”

Call to Action

The NYPD’s retaliation machine has survived four commissioners and the full term of Mayor Eric Adams, but its tactics remain unchanged. Whistleblowers are punished, truth-tellers are silenced, and those closest to them are treated as collateral.

Emilio Andino’s case is not an isolated incident. It is part of a larger civil rights crisis within the NYPD—one that calls for immediate oversight, public scrutiny, and structural reform.

“The message under Adams has been consistent,” Sanders concluded. “It’s never about reform. It’s about self-protection. And anyone—even a young recruit—who threatens that culture becomes expendable.”

Case Information

Emilio Andino v. City of New York, et al.
Index No. 155113/2025
Supreme Court of the State of New York, County of New York

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Fighting for Justice and Reform to Promote Equal Opportunity

Led by Eric Sanders, Esq., ¸ŁŔűź§. has a proven track record in civil rights litigation, representing clients in complex cases involving law enforcement misconduct and employment discrimination. Mr. Sanders, a former police officer, leverages deep insight into systemic issues facing law enforcement agencies. The firm has successfully recovered millions in damages and remains committed to promoting fairness, integrity, and meaningful reform within public institutions.

Contact: Eric Sanders, Esq.
President and Owner, ¸ŁŔűź§.
30 Wall Street, 8th Floor
New York, NY 10005
Phone: (212) 652-2782

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Read the Amended Verified Complaint

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Retired NYPD Lieutenant Quathisha Epps to File Civil Rights Lawsuit Against City of New York and NYPD Leadership Over Retaliatory Pension Clawback and Wage Theft—Calls for Immediate Rescission, Oversight, and Criminal Investigation

NEW YORK, NY — May 13, 2025 — Today, civil rights attorney Eric Sanders, Esq., of ¸ŁŔűź§., announced that retired NYPD Lieutenant Quathisha Epps will initiate litigation in New York State Supreme Court against the City of New York, the NYPD, and Police Commissioner Jessica S. Tisch, following the Department’s unlawful and retaliatory clawback of her overtime wages and pensionable earnings. This latest escalation of retaliation, executed on May 12, 2025, resulted in an immediate pension reduction of more than $60,000 annually, reflecting an actuarially projected direct loss of at least $1.5 million over her 25-year retirement.

In addition to seeking immediate rescission of the clawback and restoration of her pensionable earnings, Ms. Epps will assert claims for unpaid wages related to off-hours, overnight postings, vacation assignments, and other periods she was forced to work without proper documentation or compensation. These claims, Sanders emphasized, will significantly expand the Department’s financial and legal exposure for violations of the Fair Labor Standards Act, the New York Labor Law, Title VII, and the New York State and City Human Rights Laws.

Retaliation Masquerading as Oversight: A Pattern of Abuse Centered on Maddrey’s Misconduct

According to Sanders, this clawback is not an isolated administrative decision but the culmination of a years-long campaign of gender- and race-based retaliation, financial manipulation, and public humiliation, designed to erase Ms. Epps as a credible whistleblower against the Department’s most senior officials. This pattern, Sanders argued, was orchestrated under the direction of Police Commissioner Jessica S. Tisch, who personally authorized the weaponization of wage and pension systems to retaliate against Ms. Epps for engaging in protected activity, including reporting that former Chief of Department Jeffrey B. Maddrey sexually assaulted her inside NYPD Headquarters and the Police Academy between July 2023 and October 2024.

Despite the severity of these allegations, Maddrey publicly dismissed his conduct as an “office fling”—a statement Sanders characterizes as “an explicit admission of unlawful quid pro quo harassment under federal, state, and local civil rights law.” Under longstanding U.S. Supreme Court precedent—including and —employers are strictly liable when supervisors misuse their authority to extract sexual favors in exchange for employment benefits. In this case, Sanders argued that any misuse of overtime by Maddrey is the city’s legal liability, not Ms. Epps’s.

Systemic Abuse of Payroll and Retaliatory Weaponization Against Ms. Epps

In addition to the unlawful clawback of her pensionable earnings, Ms. Epps is also preparing to assert expanded legal claims for unpaid wages covering periods when she was required to work off-hours, during vacation time, and overnight postings at NYPD Headquarters. These claims, Sanders confirms, are currently being reconstructed from digital records, further illustrating the NYPD’s longstanding payroll dysfunction and abuse of authority. The Department’s failure to properly document or compensate Ms. Epps for this time is not an employee violation—it is a managerial failure that the Department is now weaponizing against her in retaliation for her protected disclosures.

Sanders underscores that the Department’s claim that Ms. Epps’s overtime was “tainted” by alleged quid pro quo harassment is a factual distortion and a legally unsupportable affront to basic labor and civil rights law. Under the Fair Labor Standards Act, the New York Labor Law, and Title VII, any managerial abuse of authority—including the quid pro quo harassment inflicted by Maddrey—does not negate the employer’s obligation to pay wages. Instead, it compounds liability. The employer cannot erase its misconduct by retroactively punishing the victim. As Sanders put it, “The Department’s argument is not only absurd—it is a grotesque distortion of wage protections and an assault on the rights of sexual assault survivors. Any benefit the NYPD received from Ms. Epps’s labor—no matter the conditions—remains their legal responsibility. The attempt to now criminalize her work is not oversight—it is retaliation designed to punish the victim while absolving the predator.”

Sanders warned that these continuing claims for unpaid wages will only deepen the Department’s financial and legal exposure. They will compound the liability arising from the retaliatory clawback and expose the City to additional wage theft, civil rights, and due process violations.

A Pattern of Selective Enforcement and Institutional Betrayal

Sanders’s letter further lays out how the Department’s retaliatory actions against Ms. Epps starkly contrast with its historical tolerance of incomplete, reconstructed, and retroactively approved overtime slips—a practice explicitly admitted under oath by Senior Payroll Supervisor Kenya Coger to have been routine and tolerated for over fourteen years, benefiting thousands of officers, including the Department’s top 400 overtime earners. Yet, Ms. Epps remains the only officer to have been subjected to this extraordinary and punitive clawback, underscoring the Department’s retaliatory and discriminatory targeting of a Black woman whistleblower.

Sanders notes that the department’s records reveal that in Fiscal Year 2024 alone, the NYPD overspent its uniformed overtime budget by 93%, ballooning from $1.46 billion in FY 2013 to $2.22 billion. Despite this financial mismanagement, no other officer, let alone one of the Department’s many top overtime earners, has ever faced a clawback. Only Ms. Epps was targeted, and only after she exposed Maddrey’s abuse and the Department’s complicity.

The NYPD’s Conduct Meets the Muldrow Standard for Retaliation and Constitutes Criminal Exposure

Sanders emphasized that the Department’s conduct constitutes textbook unlawful retaliation under the U.S. Supreme Court’s April 2024 decision in , 601 U.S. 338 (2024). Under Muldrow, any employment action that imposes “some harm”—whether economic, reputational, or professional—is sufficient to trigger retaliation protections under Title VII. The NYPD’s clawback of Ms. Epps’s pension and wages, public smearing of her integrity, and manipulation of payroll and pension systems inflict such harm beyond dispute.

“The NYPD’s conduct meets the Muldrow standard squarely,” Sanders stated. “This is not only retaliation in the classic sense—it is retaliation wrapped in fiscal manipulation, bureaucratic deceit, and racial and gender oppression. It is not only unlawful; it is glaringly obvious.”

Sanders further demanded that the Department’s conduct be immediately referred to the New York State Attorney General and the New York State Department of Labor for criminal investigation and prosecution under NYLL § 198-a and applicable anti-fraud, public corruption, and official misconduct statutes. By attempting to launder Maddrey’s admitted misuse of overtime through retaliatory clawbacks targeting Ms. Epps, the Department is not only obstructing justice but defrauding taxpayers and abusing public funds for personal and institutional gain.

“For any authority to suggest Ms. Epps is criminally liable is legally asinine,” Sanders declared. “Maddrey, Tisch, and the NYPD leadership misused public funds, manipulated overtime systems, and exploited Ms. Epps’s labor for their benefit. The City cannot now criminalize the victim to shield the perpetrators.”

Demand for Immediate Rescission, Accountability, and Public Disclosure

In light of these gross abuses, Sanders demanded the immediate rescission of the May 12, 2025, clawback, the complete restoration of Ms. Epps’s pensionable earnings and unpaid wages, and written assurances that no further retaliatory actions will be taken against her. All records, emails, and data associated with these retaliatory acts must be fully preserved.

Sanders placed the City on notice that if it fails to comply within ten business days, his firm will initiate civil rights litigation in New York State Supreme Court, asserting claims for quid pro quo harassment, hostile work environment, retaliation, constructive discharge, wage theft, due process violations, and retaliatory abuse of authority.

Sanders also vowed to pursue full public disclosure to the City Council, the media, and oversight agencies, ensuring that the Department’s systemic misconduct, institutional betrayal of whistleblowers, and misuse of taxpayer funds are placed squarely before the public eye.

“This is not a payroll discrepancy,” Sanders concluded. “It is the latest, most flagrant act of institutional betrayal by the NYPD’s leadership against a Black woman whistleblower. The law does not tolerate it. Neither will we.”

´Ą˛ú´ÇłÜłŮĚý¸ŁŔűź§.

Fighting for Justice and Reform to Promote Equal Opportunity

Led by Eric Sanders, Esq., ¸ŁŔűź§. has a proven track record in civil rights litigation, representing clients in complex cases involving law enforcement misconduct and employment discrimination. Mr. Sanders, a former police officer, leverages deep insight into systemic issues facing law enforcement agencies. The firm has successfully recovered millions in damages and remains committed to promoting fairness, integrity, and meaningful reform within public institutions.

Contact: Eric Sanders, Esq.
President and Owner, ¸ŁŔűź§.
30 Wall Street, 8th Floor
New York, NY 10005
Phone: (212) 652-2782

###

Read the Clawback Response

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New York, NY — Saturday, May 3, 2025 – In a formal response filed May 2, 2025, ¸ŁŔűź§., asserts that the New York City Police Department’s demand that former Lieutenant Quathisha Epps repay $231,896.75 in overtime wages is not only baseless—it is retaliatory, discriminatory, and illegal. According to the firm, this clawback demand followed closely on the heels of Epps’s disclosures of rape, sexual coercion, wage fraud, and executive misconduct involving former Chief of Department Jeffrey B. Maddrey and other NYPD senior officials.

“This is not a payroll issue,” said Eric Sanders, Esq., counsel for Ms. Epps. “This is a targeted attack on a Black woman who dared to report sexual abuse by the most powerful uniformed officer in the Department. What the NYPD is doing now is retaliation—plain and simple.”

Protected Disclosures, Retaliatory Suspension, and Public Smear

On December 18, 2024, Epps was suspended without cause. The suspension occurred immediately after she alleged that Maddrey sexually assaulted her inside NYPD Headquarters. The suspension, carried out by former Chief of Internal Affairs Miguel Iglesias, was not accompanied by any investigation into the criminal allegations. Despite her protected disclosures, Police Commissioner Jessica S. Tisch, empowered by the New York City Charter and Administrative Code § 14-115, took no action to investigate or protect her.

Between FY July 2023 and October 2024, Epps internally reported a pattern of high-level misconduct: rape, sodomy, quid pro quo harassment, wage coercion, destruction of evidence, and the abuse of departmental databases to target women. Rather than respond appropriately, the NYPD leaked manipulated overtime records to the New York Post, framing Epps as a financial opportunist.

“The overtime issue is a red herring—manufactured to distract from the real legal and moral crisis inside the NYPD. Under New York labor law, the employer must maintain accurate records, not the employee. The law is clear: administrative gaps or missing slips—especially in a system the Department itself admits is flawed—do not constitute fraud. This is not a wage dispute. It’s a retaliation case cloaked in payroll rhetoric, and the legal precedent overwhelmingly supports Ms. Epps,” says Sanders.

As the retaliation escalated, Epps was forced into retirement in bad standing. Meanwhile, those implicated—including First Deputy Commissioner Tania I. Kinsella, former Deputy Commissioner Kaz Daughtry, former Chief of Patrol John Chell, Maddrey, and Iglesias—escaped accountability.

A Legacy of Retaliation Against Black Women Who Report Abuse

Epps’s case is not an anomaly—it is a modern reenactment of a centuries-old pattern in which Black women who report sexual violence are met with disbelief, discrediting, and institutional punishment.

From slavery through Jim Crow to the modern NYPD, the legal system has consistently failed to see Black women as credible victims. The Department’s decision to pursue Epps for repayment—despite no audit, no disciplinary finding, and no evidence of wrongdoing—mirrors this legacy. Had she remained silent, no clawback would have occurred.

Her experience echoes that of Recy Taylor, the Black woman abducted and gang-raped by six white men in 1944, in Alabama. Despite a confession, no charges were brought. The case, investigated by Rosa Parks, became a national symbol of institutional complicity. So too now, Epps faces bureaucratic punishment instead of protection.

Today, silencing Black women takes more insidious forms: retaliatory transfers, unjust disciplinary actions, and character attacks. According to the Center for Employment Equity, 68% of sexual harassment charges include retaliation. Though Black women make up only 7% of the U.S. workforce, they filed 27% of all harassment complaints between 2012 and 2016. Their complaints are the least likely to succeed and the most likely to be punished.

Institutional Retaliation Disguised as Investigation

The NYPD’s campaign against Epps did not begin with a neutral audit—it started with a retaliatory media leak. Before any formal review occurred, confidential overtime records were selectively released to discredit her following disclosures of sexual assault, quid pro quo harassment, and wage coercion involving Maddrey. What followed was not a search for accountability, but a calculated retribution strategy: Epps was recast from victim to suspect. Investigatory bodies, including the Internal Affairs Bureau and Quality Assurance Division, operating under Tisch, launched internal probes anchored on “missing” records that Epps never controlled—records allegedly requested and processed under Maddrey’s authority. These inquiries, initiated only after Epps filed her EEOC Charge and cooperated with federal authorities, reflect a structural weaponization of process, not an impartial pursuit of truth. NYPD leadership allegedly used investigatory channels to preserve institutional reputation and suppress exposure, while ignoring well-established trauma science confirming that delayed reporting, memory inconsistencies, and emotional dysregulation are common and expected responses to sexual violence. Instead, Epps’s trauma responses were twisted into grounds for suspicion. These retaliatory investigations—mirroring prosecutorial misconduct seen in broader law enforcement culture—ignored testimonial credibility, destroyed physical and digital evidence, and relied on procedural pretexts to justify reputational harm and financial clawback. Under New York law, such investigations, when launched in response to protected activity, are not only suspect—they are unlawful. In this case, the Department’s internal machinery was not used to investigate misconduct—it was used to silence a woman who dared to report it.

Destruction of Evidence and Alleged Institutional Spoliation

According to the response, the NYPD’s handling of physical and digital evidence related to Epps’s sexual assault allegations constitutes not mere administrative negligence, but deliberate, unlawful spoliation. After Epps filed an EEOC Charge and began cooperating with federal and local law enforcement, the Department allegedly removed and destroyed critical evidence from the location where she reported being assaulted by Maddrey. This included her department-issued iPad, desktop computer, mobile phone, and an external drive containing confidential materials, such as “contracts” and “grids,” allegedly processed at Maddrey’s direction and inconsistent with NYPD policy. Also destroyed were personal documents, notebooks, red diaries, and the physical workspace itself—flooring, furnishings, wall treatments—erasing the crime scene.

Despite the direct evidentiary relevance of these materials and clear legal obligations under New York law and NYPD policy to preserve them, no imaging, sequestration, or preservation steps were taken. The response asserts this conduct constitutes willful spoliation and that Epps will seek an adverse inference at trial, monetary sanctions, and suppression findings under CPLR § 3126. Supporting precedent includes Pegasus Aviation I, Inc. v. Varig Logistica S.A., 26 N.Y.3d 543 (2015), and VOOM HD Holdings LLC v. EchoStar Satellite L.L.C., 93 A.D.3d 33 (1st Dep’t 2012), both of which affirm that a duty to preserve evidence attaches when litigation is reasonably anticipated—even before it is formally filed.

More broadly, the Department’s actions reflect a pattern of obstruction, not investigation. Under any reasonable probable cause analysis, these allegations should have triggered an immediate arrest and criminal referral. Instead, the Department allegedly moved to eliminate evidence, silence the complainant, and protect executive staff. What occurred, the response concludes, was not a lapse—it was an institutional cover-up carried out at public expense and in direct violation of Ms. Epps’s civil and legal rights.

Contradictory Public Testimony and Selective Enforcement Reveal Retaliatory Motive

The NYPD’s clawback demand against Epps directly conflicts with its sworn public statements and long-standing internal practices, revealing what the response calls a “strategic act of institutional retaliation cloaked in fiscal oversight.” On March 20, 2024, during a City Council budget hearing, Kinsella testified under oath that the NYPD had implemented rigorous biweekly oversight measures to monitor and control overtime expenditures. Seated beside her were then–Police Commissioner Edward A. Caban, Deputy Commissioner of Legal Matters Michael Gerber, Maddrey, Chell, and other senior command staff. None of them challenged her testimony. None disclosed that these supposed controls were inconsistently enforced or entirely abandoned.

Yet from July 2023 through October 2024—the same period Kinsella referenced—Ms. Epps’s overtime was logged, approved, and paid without objection through standard NYPD procedures. She was among hundreds of uniformed officers with comparable or higher overtime earnings. No internal inquiry was initiated. No irregularities flagged. No UF-49s issued. The scrutiny only began after she engaged in protected activity: rejecting Maddrey’s coercive advances, reporting sexual and financial misconduct internally, filing an EEOC charge, and cooperating with outside investigators. The Department’s clawback narrative—unsupported by audit findings or contemporaneous documentation—emerged only after Epps named her abuser.

This is not fiscal discipline. It is a retaliatory pretext.

The statistical context further underscores the disparity. Between Fiscal Years 2013 and 2022, New York City’s overtime costs surged by $760 million, from $1.46 billion to $2.22 billion. The NYPD accounted for the largest share. In FY 2022 alone, the department overspent its uniformed overtime budget by 93%, and by FY 2023, the City Comptroller projected NYPD overtime costs would exceed $740 million—nearly double the $374 million allocated. Assuming even a conservative estimate of 400 top overtime earners annually translates to thousands of high-compensation officers over the past decade. Yet there is no record of a single clawback—until Ms. Epps. Her selection is not coincidental. It is retaliatory.

The legal foundation for the demand is equally infirm. Under 12 NYCRR § 142-2.6, employers—including the NYPD—bear the nondelegable duty to maintain accurate payroll records for at least six years. Yet the Department has failed to produce any audit, disciplinary finding, or sworn payroll declaration to justify its $231,896.75 claim. Instead, it references “missing” or “replaced” overtime slips—records known to be inconsistently maintained and frequently corrected across commands. On July 26, 2024, a Departmental Trial involving Lieutenant Joel Ramirez and Sergeant Jose Dume, longtime payroll supervisor Kenya Coger, testified that such discrepancies were routine and corrected retroactively, without adverse consequences.

Ms. Epps’s timekeeping occurred under the same norms. At Maddrey’s direction, she and others in the Chief of Department’s Office were instructed not to use the CityTime system. Overtime was logged manually and submitted through channels that had never before triggered audit scrutiny. That this routine, manager-approved system is now retroactively criminalized—only after Epps disclosed sexual assault and wage coercion—exposes the demand as retaliatory enforcement, not neutral policy.

This weaponized clawback violates well-established labor law. As the Appellate Division held in Matter of Mid Hudson Pam Corp. v. Hartnett, 156 A.D.2d 818 (3d Dep’t 1989), employers who fail to maintain payroll records cannot shift the burden to employees. Courts may rely on testimony and reconstructed evidence in the face of incomplete records, resolving any inaccuracy against the employer who caused it.

The NYPD’s silence toward thousands of similar earners, juxtaposed with its pursuit of Epps, speaks volumes. This is not an attempt to safeguard taxpayer funds. It is an attempt to discredit a Black woman who named her abuser. The demand must be withdrawn as a matter of law, equity, and institutional accountability.

Conclusion and Call to Action

The Department’s clawback demand lacks legal foundation and moral standing. It is a targeted effort to punish a whistleblower for exposing institutional misconduct. It reflects selective enforcement, systemic payroll dysfunction, and entrenched gender and racial bias.

The City of New York and Commissioner Tisch now face a clear choice: protect the power structure or the truth. If the retaliatory demand is not withdrawn and Ms. Epps’s employment record is not corrected, ¸ŁŔűź§. will initiate litigation. Relief will include compensatory and punitive damages, injunctive relief, spoliation sanctions, and full attorney’s fees under the New York Human Rights Laws, the Gender-Motivated Violence Act, and other applicable law.

“I will not be silenced. This isn’t just my fight—it’s the fight of every woman who dared to speak up and was punished for it,” said Quathisha Epps. “If the Department—or anyone else—believes they can erase what happened by attacking me, they’ve gravely underestimated the power of truth.”

###

See NYPD Overpayment Demand

See NYPD Overpayment Response 

See DCT Trial Transcript – Ramirez Partial Day 2

See Matter of Mid Hudson Pam Corp v Hartnett

The post NYPD Retaliation Exposed: Former Lieutenant Quathisha Epps Threatens Legal Action Over $231,896 Wage Clawback Tied to Sexual Assault Whistleblower Retaliation first appeared on ¸ŁŔűź§..

Lieutenant Joel Ramirez’s lawsuit claims senior officials shielded white officers involved in misconduct while punishing him for exposing corruption, exacerbating distrust within the department and among the public.

New York, NY – April 29, 2025 – Lieutenant Joel Ramirez, a 19-year veteran of the New York City Police Department (NYPD), has filed a lawsuit in New York State Supreme Court alleging that the NYPD retaliated against him for whistleblowing and subjected him to a double standard in discipline. The suit claims that Ramirez was unfairly demoted and subjected to termination and disciplinary probation after he exposed an internal cover-up of officer misconduct. In contrast, other officers – predominantly white or politically connected – received lenient treatment for far more serious offenses. The 77-page Verified Complaint details a pattern of discrimination, retaliation, and favoritism within the NYPD’s disciplinary system, echoing longstanding concerns raised by the independent panel’s 2019 report on the NYPD, “The Report of the Independent Panel on the Disciplinary System of the New York City Police Department.”

Background: Whistleblower Alleges Cover-Up and Retaliation

According to the complaint, Ramirez served as a supervisor at the 2022 Electric Zoo music festival, overseeing narcotics enforcement and the handling of prisoner transports. During the event, several detectives were caught on video stealing expensive bottles of champagne and consuming alcohol while on duty – serious misconduct that Ramirez says he reported immediately to his superiors. Instead of disciplining the offending detectives, high-ranking officers allegedly orchestrated a cover-up. The complaint asserts that a group of commanders (including the Chief of Detectives Joseph E. Kenny, Deputy Chief Brian S. McGee, Inspector Peter A. Fiorillo, Deputy Inspecotr Christopher Henning, Deputy Inspector Daniel J. Campbell and Internal Affairs Bureau executives including former Chief of Internal Affairs David P. Barrere) intervened to shield the detectives – instructing them to change out of their uniforms and leave the scene – and then scapegoated Ramirez for “failure to supervise.”

Ramirez claims that after he objected to this cover-up and pushed for accountability, NYPD leadership retaliated with a barrage of unjust actions. He was stripped of his command, subjected to internal charges, and ultimately recommended for termination, despite the lack of any evidence to suggest that he had engaged in wrongdoing. Internal records show that the detectives who were involved in theft and alcohol misuse were largely protected by their superiors. In contrast, Ramirez – a Hispanic officer with an exemplary service record – was targeted for harsh punishment. The lawsuit alleges retaliation for whistleblowing and an act of racial and ethnic discrimination, given that the officers shielded from discipline were white and had influential connections within the NYPD’s ranks.

Ramirez’s ordeal culminated in a departmental trial on the “failure to supervise” charge, which he contends was a sham proceeding riddled with bias. The complaint alleges that NYPD officials ignored key exculpatory evidence, relied on speculative assertions instead of facts, and held him to an unreasonable standard that had never been applied to similarly situated supervisors. Despite multiple witnesses corroborating Ramirez’s proper conduct and the absence of any subordinate misconduct that he could have prevented, the trial outcome was pre-determined. In October 2024, then-Commissioner Thomas G. Donlon approved a recommendation to fire Ramirez (technically a dismissal held in abeyance for one year), effectively ending his NYPD career.

By contrast, the detectives who committed the misconduct at Electric Zoo faced minimal repercussions. The complaint notes that none of those officers were terminated; some received minor command disciplines or short suspensions at most, despite clear evidence they stole property and violated multiple department rules. “It was a complete inversion of justice,” the complaint states, alleging that NYPD leadership chose to silence the whistleblower and protect the wrongdoers. Ramirez’s suit contends that this outcome was driven by favoritism and a desire to avoid scandal, given that the involved detectives were members of the NYPD’s Gaelic Football Club – an organization with influential supporters within the department.

Favoritism and Inconsistent Discipline: Findings Mirror 2019 NYPD Panel Report

Ramirez’s allegations come against the backdrop of broader criticisms of NYPD’s disciplinary system. A high-profile 2019 Independent Panel Report on NYPD discipline, commissioned by then-Commissioner James O’Neill, warned of opaque processes, arbitrary standards, political favoritism, and systemic inconsistencies in the discipline of officers. The panel of legal experts found that officers with connections or clout often received lighter penalties, while others faced harsher outcomes for similar or lesser misconduct. In particular, the panel highlighted how political influence and personal relationships could sway disciplinary decisions: well-connected officers frequently saw their cases “quietly dismissed or faced minimal consequences,” whereas those without patronage – or those who had fallen out of favor – were subjected to severe penalties without clear justification. This double standard, the report concluded, compromised the integrity of the entire disciplinary system and raised serious concerns about transparency and fairness.

The complaint asserts that Ramirez is a textbook example of the very problems identified by the 2019 panel. It alleges that NYPD officials applied inconsistent and biased discipline: protecting favored officers while punishing Ramirez disproportionally, despite his lack of misconduct. Indeed, former Commissioner Donlon’s decision to terminate Ramirez is contrasted with multiple recent cases in which officers who committed egregious offenses retained their jobs. The complaint explicitly cites the independent panel’s findings, noting that even the perception of favoritism or bias can undermine confidence in the disciplinary system. In Ramirez’s case, that perception was reinforced by outcomes that defied logic or merit – a scenario the panel cautioned could happen in a system with little transparency and virtually unchecked discretion for top officials.

Notably, the NYPD’s disciplinary process has historically lacked public transparency due to New York’s now-repealed Civil Rights Law §50-a, which shielded police misconduct records from disclosure. The 2019 panel found that this “fundamental and pervasive lack of transparency” bred mistrust and impeded accountability. Ramirez’s experience, his lawsuit alleges, exemplifies how secretive disciplinary proceedings allow favoritism to flourish. Key decisions in his case were made behind closed doors, with no explanation provided for deviating from standard procedures. The Commissioner provided no detailed rationale for why Ramirez was singled out, creating an appearance of arbitrariness that “undermines the confidence of the public and other constituencies in the integrity and fairness of the NYPD’s disciplinary system.”

Comparator Cases Highlight Disparate Treatment

In support of his claims, Ramirez’s complaint sets forth numerous comparative cases of NYPD officers who engaged in serious misconduct but received leniency, in stark contrast to the harsh outcome he endured. These examples, spanning recent years, illustrate an alleged pattern of discipline by double standards:

• : Accused of multiple sexual encounters with a crime witness and making false statements, Thompson’s misconduct led an NYPD Trials Commissioner to recommend termination. Instead, in October 2023, Commissioner Caban overruled that recommendation and imposed only the loss of 30 vacation days and one year of dismissal probation. The complaint alleges that this decision was driven by Thompson’s political connections, which constitutes improper influence on the process.

• : Arrested for Arson (intentionally setting a fire causing property damage) and criminal mischief, Sorocco did not lose her job. She forfeited 30 days’ pay, served one year of probation, and then returned to full duty without demotion under Commissioner James O’Neill. Despite the felony-level nature of her offense, she was given an opportunity for rehabilitation that Ramirez was denied.

• : Caught submitting fraudulent COVID-19 vaccination cards and lying during an official investigation, Lucas faced charges of dishonesty. An NYPD deputy commissioner recommended termination; yet, on May 10, 2024, Commissioner Caban rejected that and levied only an 85-day vacation day loss and a one-year probation. He cited her prior good performance as justification, a tolerance not afforded to Ramirez despite his exemplary record.

• : Found guilty in two separate incidents of domestic violence and reckless endangerment against his wife, including one incident causing her serious spinal injuries, an NYPD Trials Commissioner urged that Rathour be fired for his “blatant disregard” for safety. Nevertheless, Commissioner Caban again deviated from that recommendation and imposed lesser, undisclosed penalties, which the complaint links to Rathour’s affiliations with influential NYPD figures. Rathour remained on the force, whereas Ramirez was recommended for termination for a far less egregious situation.

• : In a highly publicized case, Joseph Essig – the son of NYPD Chief of Detectives James Essig – was arrested in 2015 for felony sexual misconduct. He ultimately pleaded guilty to a minor violation and paid a fine. Rather than being disqualified from service, Essig was allowed to continue his NYPD career under Commissioner William Bratton, even securing an assignment to the elite Gun Violence Suppression Division. Ramirez notes that he was recommended for termination despite never having been convicted of any crime, while Essig kept his position after a serious arrest for a crime.

These and other cases outlined in the complaint (involving offenses ranging from DUI and child endangerment to associating with criminals and filing false reports) and indeed others unknown to Ramirez at the time, all paint a consistent picture. Officers with political clout or favored status were shielded from termination despite well-founded misconduct charges, whereas Ramirez, who lacked such connections, received the NYPD’s harshest penalty. The lawsuit alleges that this disparity is not coincidental but symptomatic of a deeply flawed system. “The NYPD’s disparate disciplinary practices demonstrate that conduct involving public intoxication, domestic violence, endangering children, obstruction of investigations, and even felony-level misconduct were not deemed fireable offenses when politically connected individuals were involved,” says Eric Sanders. In contrast, Ramirez was recommended for termination “under materially different circumstances that had little to do with merit and everything to do with retaliation and discrimination,” say Sanders.

Systemic Impact: Eroding Trust and Public Safety

Ramirez’s case raises alarms about the broader consequences of the NYPD’s alleged retaliation against whistleblowers and uneven discipline. Policing experts have long warned that a “blue wall of silence” – where officers fear reporting misconduct – can fester when whistleblowers are punished instead of rewarded. This practice deters honest cops from coming forward, enabling wrongdoing to continue unchecked. It also undermines internal accountability mechanisms, since crucial information about misconduct may never surface if officers believe speaking up will lead to retaliation.

Such a culture has dire implications for public trust and safety. When misconduct is swept under the rug and whistleblowers are ostracized, the community’s confidence in law enforcement erodes. As the 2019 independent panel noted, even the appearance of bias or favoritism in discipline “undermines the legitimacy of the disciplinary process” in the eyes of both officers and the public. Communities rely on police departments to police themselves with fairness and transparency; if, instead, the NYPD is perceived to protect insiders and punish truth-tellers, citizens may doubt whether bad officers are ever held accountable. This erosion of trust can lead to the public being less cooperative with police investigations and less likely to report crimes, ultimately harming public safety. It also demoralizes the rank-and-file officers who abide by the rules, only to see others get special treatment.

“Retaliating against a whistleblower like Lieutenant Ramirez doesn’t just violate his rights – it’s dangerous for the department and the city. It sends the worst possible signal to other officers: that integrity is unwelcome. By punishing those who speak up and rewarding those who break the rules, the NYPD fosters a culture of fear and silence. This culture not only shatters the careers of good officers, but it also deprives New Yorkers of a police department that consistently enforces standards of honesty and professionalism. In the end, it erodes public trust, and without trust, effective policing becomes impossible,” says Sanders.

The lawsuit alleges that these issues are not just individual grievances but systemic failures. It points out that NYPD officials had opportunities to intervene in Ramirez’s case and prevent a miscarriage of justice, yet at every level, the leadership ratified the retaliatory actions. Former Commissioners Keechant L. Sewell, Edward A. Caban, and Donlon – all named as defendants – allegedly either knew or should have known about the biased handling of the Electric Zoo incident but took no action to stop it. By “rubberstamping” a flawed and disproportionate penalty against a whistleblower, the suit argues, NYPD’s top brass demonstrated a tolerance for favoritism and retribution that saps morale within the force and damages the NYPD’s reputation in the community. This has prompted calls for stronger external oversight of NYPD discipline and better legal protections for officers who come forward with information about misconduct.

Lawsuit and Relief Sought

Ramirez’s Verified Complaint, filed April 29, 2025, asserts causes of action under the New York State and City Human Rights Laws, including claims of racial/national origin discrimination and unlawful retaliation. It seeks reinstatement to his position, back pay and benefits, and compensatory and punitive damages for the harm to his career and reputation.

This case arrives at a time of heightened scrutiny of NYPD’s disciplinary practices. In recent years, the Department has publicly committed to improving transparency and consistency, for example, by publishing a disciplinary penalty guidelines matrix to “eliminate the perception of favoritism or bias” in punishment. Ramirez’s experience, however, suggests that entrenched cultural problems remain. His lawsuit will shed light on whether NYPD leadership has truly broken from past patterns of favoritism, political interference, and retaliation, or whether more profound change is still needed to ensure that all officers are held accountable under the same fair standards.

Contact:

Eric Sanders, Esq.
¸ŁŔűź§.
30 Wall Street, 8th Floor
New York, NY 10005
Phone: (212) 652-2782

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Read the Verified Complaint

Read the 2019 Independent Panel Report – NYPD Disciplinary System

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NEW YORK, NY – April 27, 2025 – Civil Rights Attorney Eric Sanders, Esq., of ¸ŁŔűź§., announced today that former NYPD Police Officer Jermack Romero has filed a Verified Complaint in the Supreme Court of the State of New York, County of New York, against the City of New York, former Police Commissioners Edward A. Caban and Keechant L. Sewell, and former Deputy Commissioner Amy J. Litwin. The lawsuit alleges pervasive gender-based discrimination, unlawful reliance on a sealed arrest record, retaliation for asserting protected rights, and systemic favoritism based on political affiliations within the New York City Police Department’s disciplinary process.

The case, Romero v. The City of New York, et al., centers on Romero’s termination from the NYPD after a seventeen-year career marked by exemplary service. The Verified Complaint outlines in exhaustive detail how Romero was subjected to harsher disciplinary actions than similarly situated officers, in violation of the New York State Human Rights Law (NYSHRL) and New York City Human Rights Law (NYCHRL).

“This case highlights the NYPD’s persistent failure to uphold the principles of fairness and equal treatment in its disciplinary processes,” said Attorney Eric Sanders. “Instead of recognizing Mr. Romero’s rights, the Department reinforced gender stereotypes, disregarded legal protections afforded to individuals with sealed arrests, and weaponized internal discipline to favor politically connected individuals while punishing those without such affiliations.”

Allegations of Gender Discrimination and Gender Stereotyping

According to the Verified Complaint, Romero was accused in 2021 of domestic violence by a young female acquaintance with whom he had a close personal relationship. Despite the dismissal and sealing of the criminal charges in January 2022, the NYPD continued disciplinary action against Romero, culminating in his termination.

Romero alleges that NYPD officials presumed, based on gender stereotypes, that he was the primary aggressor in the domestic dispute. The disciplinary tribunal, led by Deputy Commissioner Trials Rosemarie Maldonado and Assistant Deputy Commissioner Vanessa Facio-Lince, systematically dismissed Romero’s claims of self-defense and disregarded credible exculpatory evidence.

Romero’s complaint further outlines how male officers like himself faced heightened scrutiny and harsher penalties in domestic incidents compared to similarly situated female officers, who often received lenient treatment or had charges dismissed outright.

“The NYPD’s disciplinary system operates on the harmful assumption that male officers are inherently guilty in domestic disputes,” Sanders said. “This presumption deprived Mr. Romero of a fair hearing and reflects a broader pattern of gender-based discrimination.”

Arrest Record Discrimination in Violation of State and City Law

The lawsuit further alleges that the NYPD unlawfully relied on Romero’s dismissed and sealed arrest record to initiate and sustain internal disciplinary charges, in direct violation of New York Criminal Procedure Law §§ 160.50 and 160.60, as well as protections afforded under the New York State Human Rights Law (Executive Law § 296(16)) and the New York City Human Rights Law (Administrative Code § 8-107(11)).

Under CPL §§ 160.50 and 160.60, once criminal charges are dismissed and sealed, the underlying arrest is deemed a nullity; the individual is to be treated as if the arrest and proceedings had never occurred. New York courts have consistently held that sealed arrests cannot serve as the basis for employment decisions, including disciplinary action, unless an employer can establish independent evidence of misconduct that bears a direct relationship to job performance or creates an unreasonable risk to public safety.

Romero contends that despite these clear legal mandates, the NYPD, through its Department Advocate’s Office, led at the time by Litwin, improperly prosecuted him by relying on the allegations associated with his dismissed and sealed arrest. The Verified Complaint asserts that the Department Advocate presented no new, independent evidence beyond the sealed incident and failed to demonstrate any direct relationship between the dismissed allegations and Romero’s fitness to serve as a police officer or any unreasonable risk to public safety.

Romero’s claims are consistent with recent judicial findings where courts have repeatedly criticized the NYPD for violating sealed records statutes in internal disciplinary proceedings. In decisions such as Matter of Anonymous v. New York City Police Department and Holloway v. City of New York, courts emphasized that NYPD disciplinary bodies must respect the legal finality and confidentiality protections associated with sealing statutes and cannot simply re-prosecute dismissed allegations under the guise of internal discipline.

“The NYPD’s use of Mr. Romero’s sealed arrest record was not merely a procedural irregularity — it was a fundamental violation of state law and well-established public policy protecting individuals from being stigmatized based on arrests that the criminal justice system has explicitly wiped away,” said Sanders. “The entire purpose of sealing is to ensure that people are not continually punished or discriminated against because of unfounded accusations. In Mr. Romero’s case, the NYPD showed blatant disregard for that protection.”

Sanders added, “By weaponizing a sealed arrest against Mr. Romero, the Department violated not only the letter of the law but also the spirit of fairness and rehabilitation that underpins New York’s sealing statutes. This misconduct further underscores the systemic flaws in the NYPD’s disciplinary system that this lawsuit seeks to expose and remedy.”

Arbitrary Discipline, Systemic Favoritism, and Senior Official Misconduct

Romero’s Verified Complaint meticulously documents a pattern of arbitrary, biased, and politically motivated disciplinary outcomes within the NYPD, exposing a deep culture of favoritism protected and perpetuated by the Department’s most senior officials.

Among the comparators cited:

• Police Officer Willie Thompson: Engaged in sexual relations with a female witness during an active carjacking investigation. Despite a tribunal recommendation of termination, Caban intervened, overturning the decision and imposing only a 30-day loss of vacation time and dismissal probation.

• Police Officer Kimberly Lucas: Pleaded guilty to falsifying COVID-19 vaccination documents — an act of fraud and misconduct undermining departmental integrity. Again, although termination was recommended, Caban reduced the penalty to a mere forfeiture of vacation days and probation.

• Sergeant Omar Salem: Committed domestic violence against his spouse but was never arrested or terminated, receiving only minor internal discipline despite credible allegations of physical abuse under former Commissioner Dermot F. Shea.

• Detective Marissa Sorocco: Found guilty of intentionally setting fire to marital property in an arson incident, yet allowed to retain her title and only suffered minimal penalties under former Commissioner James P. O’Neill.

• Police Officer Delare Rathour was found guilty of engaging in two separate incidents of domestic violence and reckless endangerment against his wife. In the first incident, Rathour shoved his wife into a closet, causing serious spinal injuries. In the second incident, despite an active order of protection, Rathour drove recklessly with his wife in the vehicle, running red lights and endangering her life, all of which was captured on video. Assistant Deputy Commissioner Jeff Adler strongly recommended Rathour’s termination after finding a blatant disregard for public and familial safety. Nevertheless, Caban deviated from this recommendation and imposed lesser penalties, allegedly due to Rathour’s political affiliation with influential individuals in the NYPD.

These officers, who engaged in serious and sometimes criminal conduct, were shielded from termination due to personal and political affiliations with NYPD leadership. In contrast, Romero, with no political ties and facing only a dismissed and sealed arrest, was subjected to disproportionately harsh treatment, culminating in termination.

More troubling, Romero’s Complaint alleges that favoritism was not limited to rank-and-file officers. Senior NYPD leadership, including multiple past Police Commissioners, routinely violated NYPD Patrol Guide regulations prohibiting association with individuals engaged in criminal conduct. Romero details how senior executives frequently socialized with the principal of a Bronx restaurant who publicly admitted to a criminal history involving narcotics trafficking, prostitution, and related activities.

Despite clear prohibitions against associating with persons reasonably believed to be engaging in criminal conduct, these relationships were tolerated and normalized within the NYPD’s upper ranks, without any disciplinary consequences.

“How can the NYPD claim to enforce standards of conduct among its officers when its leadership blatantly violates them?” asked Sanders. “The same officials who terminated Mr. Romero based on a dismissed and sealed arrest continued to maintain improper relationships with individuals tied to organized criminal activity — yet faced no investigation, no charges, and no accountability.”

Romero alleges that this deeply entrenched culture of favoritism corrupted the disciplinary system from the top down. The seriousness of the misconduct did not determine termination and discipline, but by the political connections of the accused — a system that punished the politically unprotected while shielding those with connections.

“The message was clear: loyalty and relationships mattered more than integrity and fairness,” Sanders said. “The NYPD’s leadership created and maintained a two-tiered system — rewarding insiders and sacrificing those who dared to assert their rights.”

The Verified Complaint asserts that this systemic favoritism, gender-based discrimination, unlawful reliance on sealed arrests, and retaliation for protected activities ultimately led to Romero’s wrongful termination, causing devastating economic, emotional, and reputational harm.

Retaliation for Asserting Protected Rights

In addition to discrimination, Romero claims he was retaliated against for asserting his rights under New York’s civil rights laws. After raising defenses based on self-defense, gender bias, and sealed arrest protections during the disciplinary process, Romero states that disciplinary charges were escalated, and threats of termination increased.

According to the Verified Complaint, Caban and Sewell permitted this retaliation to proceed unchecked, further evidencing a coordinated effort to punish Romero for exercising his protected rights.

“Instead of correcting the discriminatory process, senior leadership retaliated against Mr. Romero for standing up for himself,” Sanders said. “Retaliation for asserting legal rights is unlawful and morally reprehensible.”

Relief Sought

Romero’s Verified Complaint demands compensatory damages, punitive damages, back pay, front pay, lost pension rights, reinstatement or comparable equitable relief, and attorney’s fees and costs.

The action also seeks a declaratory judgment finding that the Defendants’ conduct violates the New York State Human Rights Law and the New York City Human Rights Law, including their amendments that require independent and liberal interpretation under the Local Civil Rights Restoration Act of 2005.

“The culture of bias, favoritism, and retaliation within the NYPD cannot continue unchecked,” Sanders said. “Through this lawsuit, Mr. Romero seeks justice not just for himself, but to hold officials accountable and protect future officers from similar mistreatment.”

About ¸ŁŔűź§.

Fighting for Justice and Reform to Promote Equal Opportunity

Led by Eric Sanders, Esq., ¸ŁŔűź§. has a proven track record in civil rights litigation, representing clients in complex cases involving law enforcement misconduct and employment discrimination. Mr. Sanders, a former police officer himself, leverages deep insight into systemic issues facing law enforcement agencies. The firm has successfully recovered millions in damages and remains committed to promoting fairness, integrity, and meaningful reform within public institutions.

Contact: Eric Sanders, Esq.
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Phone: (212) 652-2782

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Rodriques, who is Black and of Jamaican descent, was appointed in 2023 as the Integrity Control Officer (ICO) of the 34th Precinct in Washington Heights. The position is designed to ensure ethical compliance and accountability within the command. But according to the complaint, the role quickly placed him at odds with a robust network of officers led by Commanding Officer Aneudy Castillo, Executive Officer Erickson Peralta, and Special Operations Lieutenant Michael J. Disanto—supervisors who, the lawsuit alleges, engaged in systemic corruption and retaliated against him for refusing to participate.

A Culture of Selective Enforcement and Political Protection

At the heart of the lawsuit is a disturbing allegation: that law enforcement at the 34th Precinct was not guided by public safety or departmental policy, but by private interest and political favoritism. The complaint identifies James Caban, the twin brother of then–Police Commissioner Edward A. Caban, as a central figure in what Rodriques calls a “protection racket” operating inside the NYPD. According to the complaint, Castillo and James Caban maintained a covert alliance in which precinct enforcement decisions—including which businesses to target and which to ignore—were shaped by Caban’s personal relationships and undisclosed interests.

Rodriques alleges that nightlife venues and businesses in Washington Heights with ties to James Caban were categorically insulated from enforcement. Officers were instructed to disregard complaints, avoid making arrests, and even suppress 311 calls involving these locations. When officers attempted to do their jobs, they were overruled. Castillo, often from his own home, would call precinct supervisors to ensure that enforcement was halted. Officers who complied were rewarded; those who questioned the directives were marginalized.

According to the lawsuit, this secret arrangement was not only known to Castillo’s leadership team but also enforced as policy. When Rodriques raised concerns about this illegal conduct, he was met not with internal review but with hostility.

Retaliation Begins: From ICO to Target

Rodriques’s refusal to participate in what he described as unlawful favoritism made him a liability to his command. Instead of being praised for upholding NYPD values, he was excluded from meetings, reassigned, denied overtime, and ultimately stripped of his responsibilities as an ICO. His authority eroded, and his professional standing was targeted.

The retaliation deepened when Castillo and his lieutenants began referring to themselves as “the mafia.” This was not hyperbole. According to the Verified Complaint, Rodriques was warned that if he had a problem with one of them, “he had a problem with the entire family.” That family, the lawsuit alleges, included other supervisors and insiders who viewed loyalty to Castillo, rather than the law, as the top priority. For Rodriques, the message was clear: integrity had become a threat to power.

The Overtime Racket and Financial Retaliation

The Verified Complaint further details a scheme of financial misconduct involving fraudulent overtime assignments. While favored officers like Lieutenant Disanto and his driver, Officer Vincent Bracco, were allegedly guaranteed at least 40 hours of overtime per month—regardless of actual duty—Rodriques was deliberately excluded from these opportunities, despite his rank, qualifications, and availability.

Even worse, overtime codes designated for public safety deployments, such as responses to Israeli protest-related threats, were repurposed to pay insiders without justification. Disanto was promoted to Lieutenant Special Assignment, not based on merit, but as a reward for loyalty to Castillo’s leadership. Meanwhile, Rodriques’s overtime was withheld, and he was systematically denied professional development opportunities as further punishment for his resistance.

Weaponized Psychological Review and Medical Harassment

In a move reminiscent of NYPD’s historical use of psychological referrals to silence whistleblowers—especially Black and Caribbean officers—Rodriques was ordered to submit to repeated evaluations by Psychological Services. Despite having no history of mental health concerns and no incidents that would justify such a referral, he was stripped of his firearm and reassigned to restricted duty. The psychological review, the lawsuit asserts, was not intended to protect him or the public. It was a weapon wielded to discredit and isolate him.

The harassment continued while Rodriques was on approved medical leave for a serious cardiac condition. Castillo repeatedly called him, accusing him of “playing sick” and demanding that he work from home, even though such demands directly violated his treating physician’s instructions. On several occasions, Castillo launched profanity-laced tirades during these calls, which were loud enough for Rodriques’s ten-year-old child to overhear, causing emotional distress that extended beyond the officer to his family.

Public Disclosure Forces Sudden Reinstatement

On February 13, 2025, Rodriques filed a formal Charge of Discrimination with the U.S. Equal Employment Opportunity Commission. In that charge, he outlined the racial and gender discrimination, hostile work environment, and retaliatory abuse he had endured. Two days later, he gave an interview to the New York Post detailing the allegations. The article went public on February 15, 2025, and within days—after nearly a year of unexplained restricted duty and coerced psychological evaluation—Rodriques was suddenly and quietly restored to full duty.

No explanation was ever provided for his prior restriction, and no findings were issued to justify the psychological referral. The lawsuit contends that the timing of this abrupt reinstatement underscores the retaliatory nature of the NYPD’s actions—and its desire to avoid public scrutiny.

Retaliation Escalates: The Ortiz Lawsuit and Internal Complaint

Within four days of the New York Post article’s publication, Sergeant Christina Ortiz filed a civil defamation lawsuit and internal discrimination complaint against Rodriques. Ortiz, who the lawsuit alleges had engaged in an inappropriate sexual relationship with Lieutenant Disanto inside 34th Precinct offices, claimed that Rodriques defamed her. But the lawsuit sees the filing as something more: a retaliatory strike, filed at the exact moment Rodriques was gaining public and legal support.

According to the Verified Complaint, Ortiz was never investigated for her misconduct. No questions were asked about the evidence left behind in precinct offices, including broken nails and the abandonment of her domestic violence unit responsibilities. Instead, Ortiz was promoted to the Internal Affairs Bureau, the very unit responsible for investigating misconduct like her own.

The complaint argues that the department’s failure to review Ortiz’s claims, coupled with her promotion, reveals the NYPD’s willingness to protect insiders and weaponize legal processes to silence dissenters.

A Lawsuit for Accountability, Not Just Relief

Lieutenant Rodriques’s lawsuit asserts ten causes of action under the New York State and New York City Human Rights Laws. These include race discrimination, gender discrimination, hostile work environment, and retaliation for protected activity. Two distinct causes of action are also dedicated to retaliatory abuse of legal and internal processes, specifically naming the City of New York and Ortiz for filing a baseless lawsuit and internal complaint shortly after Rodriques’s EEOC charge and media disclosures.

The complaint names Edward A. Caban, the former Police Commissioner, as a defendant, not solely for his familial relationship to James Caban, but also for his institutional inaction. According to the lawsuit, Caban knew or should have known about the protection racket operating within the 34th Precinct, yet took no steps to intervene. His silence, the complaint asserts, was not neutrality but ratification. And it was under his leadership that Rodriques’s career was nearly destroyed for doing his job.

A Broader Call for Structural Change

According to attorney Eric Sanders, the case is about far more than one officer’s mistreatment. It is a window into how the NYPD preserves power by protecting misconduct, retaliating against whistleblowers, and weaponizing internal procedures against officers who speak up. Rodriques, Sanders emphasizes, is the kind of officer the public wants: ethical, observant, and committed to fairness. Yet for trying to uphold the law, he was punished by the very institution charged with enforcing it.

“This is not just a hostile work environment,” Sanders said. “It is a retaliatory, coercive culture that treats integrity as a threat. Lieutenant Rodriques followed the rules. He did the right thing. And for that, his reputation, career, and health were attacked. This lawsuit seeks justice not only for him, but for every officer who has been told to ‘shut up or be silenced.’”

The Verified Complaint seeks compensatory and punitive damages, declaratory relief, and structural change. It calls for a full accounting of NYPD’s internal retaliation practices, an independent review of political interference in enforcement decisions, and reform of psychological referral protocols to prevent future abuse.

As the litigation progresses, the case is expected to shed light on long-standing issues within the NYPD’s command culture—problems that cannot be resolved through training alone but require transparency, courage, and an unwavering commitment to justice.

Contact:

For media inquiries, legal commentary, or to support Mr. Andino’s case, contact:

¸ŁŔűź§.
30 Wall Street, 8th Floor
New York, NY 10005
ąĘłó´Ç˛Ôąđ:Ěý212-652-2782

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New York, NY — April 20, 2025,  a scathing new lawsuit filed in New York County Supreme Court alleges that the New York Police Department subjected recruit Emilio Andino, a Black male assigned to the Police Academy’s “Hook Company 24-56,” to racial harassment, sexualized abuse, and institutional retaliation due to his familial connection to former NYPD Lieutenant Quathisha Epps—a high-profile whistleblower who publicly accused ex-Chief of Department Jeffrey B. Maddrey of quid pro quo sexual harassment and executive misconduct.

Filed by civil rights attorney Eric Sanders of ¸ŁŔűź§., the lawsuit asserts that the retaliation against Andino began immediately after Epps filed a Charge of Discrimination with the U.S. Equal Employment Opportunity Commission (EEOC) on December 21, 2024, and publicly named Maddrey during a same-day interview with the New York Post.

“This case exemplifies how institutions retaliate not only against whistleblowers—but also those connected to them,” said attorney Eric Sanders. “Andino didn’t violate policy, commit a crime, or fail to perform. He was targeted because of who his aunt is and what she dared to expose.”

Protected Activity Turns to Institutional Backlash

According to the Verified Complaint, Andino was sworn into the NYPD Police Academy on October 30, 2024, and assigned to Hook Company 24-56—an honor extended to recruits with familial NYPD ties. His maternal aunt, former Lieutenant Quathisha Epps, had a well-known record of integrity and had actively guided Andino’s entry into the department.

That changed dramatically on December 21, 2024, when Epps filed a formal EEOC charge naming Maddrey and detailing a pattern of sexual coercion, institutional favoritism, and executive retaliation. On the same day, she gave an on-the-record interview to the New York Post.

By the following morning, Andino’s experience inside the Academy shifted from pride to paranoia. Rumors swirled about his aunt’s sexual history. Recruits and instructors alike made degrading comments, suggesting nude photos and sex tapes of Epps were circulating. Instructors said nothing. Fellow recruits whispered in hallways and locker rooms, and Andino became a proxy target in what the lawsuit describes as “an institutional campaign of reprisal.”

A Racially Charged Confrontation

The lawsuit focuses on a critical incident that occurred on April 1, 2025, involving fellow recruit Bahron Asliev, a white male who had repeatedly made racially hostile comments throughout the Academy. Witnesses allegedly heard Asliev use the phrase: “Act like a n****, get treated like a n.”*

On that day, during a courtroom testimony training exercise on the sixth floor of the Academy, Andino gave Asliev feedback following the drill. Asliev exploded in response, reportedly saying: “Well if you could’ve done better, why didn’t you volunteer? You’re just a p**** and a bitch.”

As the class was dismissed and recruits moved down the stairwell, Asliev continued the abuse. On the third-floor landing, he confronted Andino face-to-face, saying: “What are you going to do if I don’t shut up?” When they reached the first floor, Asliev escalated again, stating: “You and your 12-year-old son can suck my d***.”

In shock, Andino raised his hands to create distance. His hand made incidental contact with Asliev’s face. That moment became the pretext for immediate and one-sided disciplinary action.

A Biased and Retaliatory Investigation

The complaint alleges that supervising sergeant JOHN DOE 1 rushed in failed to ask any questions, and immediately began treating Andino as the aggressor. Surveillance cameras line the stairwells and lobby, yet no one—including Internal Affairs, the Office of Equity and Inclusion, or Academy staff—reviewed the footage.

Lieutenant Elizabeth M. Laboy and Lieutenant arrived next. Instead of conducting a neutral inquiry, they allegedly spent “inordinate amounts of time” with Asliev, comforting him and casting him as a victim. Meanwhile, Andino was isolated, closely monitored, and reportedly denied even a basic wellness check. His 12-year-old son, present that day, was left unattended.

Hours later, around 12:30 a.m. on April 2, PBA Delegate and a PBA attorney met with Andino. After hearing his full account, they allegedly advised him to resign, warning that failure to do so would result in permanent exclusion from City employment. Neither Henry nor the PBA attorney contacted Internal Affairs or OEI, violating clear NYPD protocols.

At approximately 12:45 a.m., Andino was formally interviewed by an investigative unit, including JOHN DOES 2–5 and a supervising JOHN DOE 6, believed to be a chief. Present for the interview were Henry and Tynan. Despite Andino’s clear and complete statement, he was immediately suspended without pay. No disciplinary action was taken against Asliev.

Systemic Silence: Witnesses Intimidated

The complaint details how other recruits each overheard Asliev bragging about provoking Andino and using racial epithets. One recruit, shocked by the comment “If you act like a n****, get treated like a n,”* confronted Asliev. Yet none of the three officers reported the behavior.

Why? According to the lawsuit, they had witnessed what happened to Andino—how speaking up would end a career before it even began. NYPD training emphasized reporting, but NYPD culture discouraged it.

Different Commissioner, Same Result: From Sewell to Tisch—All Under Adams, Retaliation Still Rules the NYPD

Despite a rapid succession of police commissioners under Mayor Eric Adams, the NYPD’s entrenched culture of retaliation has remained untouched. From Keechant Sewell to Edward A. Caban, then Thomas G. Donlon, and now Jessica Tisch, the leadership may have changed. Still, the department’s treatment of those who dare to challenge power, especially whistleblowers and their families, has not.

Commissioner Keechant Sewell, the first woman to lead the NYPD, presided over the early period of internal tension involving Maddrey. Despite being aware of Epps’ complaints and the growing friction, she took no public or institutional steps to curb the retaliatory culture that was forming in response.

Edward A. Caban succeeded her in July 2023. As the department’s first Latino commissioner, there was hope for reform, but Caban’s brief tenure showed continued deference to internal politics.

On September 13, 2024, Thomas G. Donlon—a former FBI counterterrorism agent—was appointed as Police Commissioner following the resignation of Edward A. Caban. According to the lawsuit, it was during Donlon’s brief tenure that the retaliatory environment inside the NYPD Police Academy escalated significantly. Despite rising internal concerns and Andino’s worsening treatment, no institutional safeguards were implemented. No protocols were enforced. No inquiries were launched. Under Donlon’s leadership, the department failed to intervene, allowing harassment, bias, and retaliation to deepen unchallenged.

By the time Jessica Tisch was appointed in late November 2024, Andino had already been suspended without pay, his reputation tarnished, and no action was taken against the fellow recruit who had allegedly harassed him. Under Tisch’s command, nothing changed. Video evidence wasn’t reviewed. Witness statements weren’t gathered. The Office of Equity and Inclusion remained silent. The institutional message, according to the lawsuit, was clear: protecting whistleblowers-or their relatives—was not a priority.

“Andino’s case shows us what happens when leadership becomes a revolving door, but the machinery of retaliation never stops turning,” said Sanders. “Sewell ignored it. Caban enabled it. Donlon was compromised. Tisch refused to act. And through it all, Mayor Adams stood at the helm, watching his department punish the innocent.”

Although the lawsuit formally names Maddrey, numerous officers, and the City of New York, its implications extend well beyond the individual defendants. It asks a fundamental question of the Adams administration: How many more changes in title will it take before someone takes responsibility?

“The message under Adams has been consistent,” Sanders concluded. “It’s never about reform. It’s about self-protection. And anyone—even a young recruit—who threatens that culture becomes expendable.”

Maddrey’s Central Role

The complaint reserves particular condemnation for , who retired from the NYPD in December 2024, just days after Epps’ complaint and the Post article went public.

As Chief of Department, Maddrey wielded significant authority over training, internal discipline, and the Academy’s chain of command. The complaint alleges that he had direct knowledge of the retaliation against Epps and made no attempt to mitigate foreseeable harm to her family. His failure to act, the lawsuit claims, functioned as a “tacit endorsement of reprisal.”

The complaint also reveals that Maddrey had a lengthy disciplinary record, including substantiated findings by the Civilian Complaint Review Board (CCRB) and a 2017 internal guilty plea related to obstructing an investigation involving an alleged “consensual” sexual relationship with a subordinate. Despite this, Maddrey continued to rise through the ranks of the NYPD.

Andino’s lawsuit follows separate pending lawsuits involving Maddrey, filed by Captain Gabrielle Walls and advocate Dana Rachlin, both of whom allege retaliation tied to sexual harassment or whistleblowing.

The Legal Claims

The Verified Complaint asserts eight causes of action under the New York State Human Rights Law (NYSHRL) and New York City Human Rights Law (NYCHRL), including:

• Race Discrimination

• Gender Discrimination

• Hostile Work Environment

• Retaliation

• Aiding and Abetting by supervisors and peers

Andino seeks compensatory and punitive damages, a declaratory judgment, and attorneys’ fees. He has not brought federal constitutional claims at this stage.

“This was not an internal misunderstanding—it was a calculated, institutional response to a whistleblower’s family member,” said Sanders. “The City has to reckon with how it retaliates not just directly, but through proxy punishment.”

A Department-Wide Crisis of Accountability

The press release concludes with a broader call for transparency, accountability, and reform. The NYPD’s retaliatory culture, the complaint argues, doesn’t merely silence victims—it discourages witnesses, protects misconduct, and perpetuates discriminatory systems.

“This case is about more than Emilio Andino,” said Sanders. “It’s about what happens when a department tolerates misconduct at the top, punishes truth-tellers, and makes compliance a condition of survival.”

As of today, the case remains pending in New York County Supreme Court.

Contact:

For media inquiries, legal commentary, or to support Mr. Andino’s case, contact:

¸ŁŔűź§.
30 Wall Street, 8th Floor
New York, NY 10005
ąĘłó´Ç˛Ôąđ:Ěý212-652-2782

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New York, NY – April 18, 2025 — In a sweeping and detailed complaint filed with the U.S. Equal Employment Opportunity Commission (EEOC), veteran NYPD Police Officer Frankie F. Palaguachi has accused the New York City Police Department and its drug-testing contractor, Psychemedics Corporation, of operating a racially biased and scientifically flawed testing methodology that disproportionately impacts officers of color—particularly Latino and Black members of the service—through the use of controversial Radioimmunoassay of Hair () hair-based drug testing.

The administrative charge, filed under Title VII of the Civil Rights Act of 1964 and its state and local equivalents, outlines a deeply troubling pattern: facially neutral drug testing methods implemented without oversight, scientific validation, or legal compliance, resulting in discriminatory outcomes, career-altering punishments, and retaliation against officers who raise concerns. The complaint names both the NYPD and Psychemedics as respondents, citing their interdependent roles in administering, interpreting, and enforcing drug test results without safeguards, procedural fairness, or adherence to federal regulatory standards.

“What we see here is not mere oversight—it’s institutional insensitivity. The NYPD has allowed flawed science and opaque processes to dictate discipline without regard for fairness, accuracy, or humanity. Officers of color are disproportionately harmed, yes—but this regime endangers all officers, regardless of race. It’s a system cloaked in the false legitimacy of ‘randomness,’ while political insiders are protected and outsiders are punished. That’s not justice—it’s structural betrayal.”
— Eric Sanders, President of ¸ŁŔűź§.

“I saw this coming years ago when I was president of the Guardians Association of the Police Department City of New York. Even then, when the Department first proposed using hair testing, the scientific and civil rights concerns were already obvious. Since that time, researchers and members of the scientific community have repeatedly confirmed what many of us warned: this method is unreliable, racially biased, and ripe for abuse. Frankly, I’m stunned that the unions haven’t mounted a serious challenge. This isn’t just a policy failure—it’s a betrayal of the very people who risk everything in uniform, says Sanders.”

A “Random” Drug Test That Was Anything But

According to the charge, Officer Palaguachi—a decorated officer with no history of misconduct—was notified on February 22, 2024, that he had been selected for a “random” drug test. However, the selection was not announced via the NYPD’s Finest Message system, which is the standard method for notifying members of service about random drug screenings. Instead, the notice came via an undocumented phone call. Palaguachi, who had recently raised internal concerns about discriminatory treatment and testing practices within the department, immediately questioned the timing and legitimacy of the selection.

Upon arrival at the NYPD Medical Division, Palaguachi was subjected not to a standard urinalysis test, but to radioimmunoassay of hair (RIAH)—a method of drug testing that analyzes strands of hair to detect drug metabolites over a 90-day window. While marketed as more comprehensive than urine screening, RIAH has never been approved by the Substance Abuse and Mental Health Services Administration () for use in federal workplace testing due to its inability to distinguish between environmental contamination and ingestion, its destructive testing method, and well-documented racial disparities in drug retention among darker-haired individuals.

Palaguachi’s sample was analyzed by Psychemedics Corporation, the City’s long-time testing vendor. The results, according to the charge, were inconsistent with science-based cutoff levels and later contradicted by multiple independent drug screenings, a polygraph, and a court-admissible toxicology exam. Nonetheless, the NYPD used the test to suspend Palaguachi without pay, demote him, and begin disciplinary proceedings.

Racial Bias Baked Into the Science—and Ignored by the NYPD

As the charge outlines, RIAH testing has long been criticized in the scientific community for its racialized outcomes. —the pigment that gives hair its dark color—has a high affinity for certain drug compounds, such as cocaine and THC. Studies have shown that individuals with darker, coarser hair, such as African American and Hispanic populations, are more likely to bind drug residues even from passive exposure, resulting in a higher rate of false positives when compared to those with lighter hair.

This biological disparity is not hypothetical. In , 845 F.3d 28 (1st Cir. 2016), the U.S. Court of Appeals permitted a Title VII disparate impact claim to proceed after finding statistical and scientific evidence that the Boston Police Department’s use of hair testing disproportionately harmed Black officers. In that case, the court acknowledged the unreliability of hair testing in distinguishing between actual use and surface contamination, particularly in racially diverse populations.

The EEOC charge filed by Palaguachi explicitly references this case and similar scientific literature, noting that the NYPD continues to use RIAH testing despite the lack of federal endorsement, the known bias against officers of color, and the destructive, non-verifiable nature of the method. No split sample is retained. No DNA authentication is performed. And officers are not permitted to verify the results through reanalysis or appeal independently.

Pattern or Practice of Discrimination and Retaliation

The charge further alleges that the NYPD’s testing program is not merely flawed—it is systematically discriminatory. The Department does not conduct statistical monitoring of testing outcomes by race, sex, or ethnicity, as required by the Uniform Guidelines on Employee Selection Procedures (), 29 C.F.R. § 1607. Nor does it provide employees with access to the algorithm that determines who is selected for testing. The entire process, according to the charge, is shrouded in secrecy and devoid of procedural safeguards.

The EEOC filing identifies a broader pattern of misconduct:

• Officers of color are subjected to hair testing at higher rates than white officers.

• Unequal disciplinary outcomes for similarly situated employees—some white officers with positive results reinstated quietly, while officers of color are demoted or terminated.

• Refusal by the NYPD to disclose comparator data or trial decisions, thereby obstructing efforts to challenge discriminatory enforcement.

• Use of the drug testing program as a mechanism of retaliation against officers who question internal practices, raise discrimination claims, or advocate for reform.

Palaguachi’s case, the charge asserts, is not an isolated incident but part of a “pattern or practice” of using drug testing as a proxy for racial targeting, political suppression, and retaliation against dissenters.

Psychemedics: The Silent Gatekeeper

While the NYPD carries out the disciplinary action, the charge squarely names Psychemedics as a co-respondent. The Texas-based laboratory, a major player in the hair testing industry, is the City’s exclusive vendor for RIAH screening. It conducts the initial screening, confirmatory testing, and issues the final report that often forms the basis for career-ending decisions.

Critically, Psychemedics operates behind closed doors. The cutoff thresholds it uses are proprietary. The sample is consumed during testing, eliminating any opportunity for independent verification. And officers have no right to challenge the lab’s methods or demand a third-party review. This lack of transparency, the charge argues, creates a due process vacuum—one that disproportionately affects officers of color and whistleblowers.

Under Title VII and UGESP, employers cannot delegate away their responsibility to ensure that testing methods are valid, nondiscriminatory, and scientifically sound. Nor can they rely on third-party vendors whose practices have not been independently audited or validated for fairness and compliance.

Yet, according to the charge, the City of New York has done precisely that—outsourcing life-altering decisions to a private contractor whose procedures remain shielded from scrutiny.

Legal Framework: Title VII, § 1983, NYSHRL, NYCHRL—and More

The legal claims asserted in the charge are far-reaching. They include:

• Title VII: Disparate impact and disparate treatment based on race and national origin; hostile work environment; retaliation.

• 42 U.S.C. § 1983: Equal Protection Clause violations for race-based selective enforcement; First Amendment retaliation for protected whistleblowing.

• New York State Human Rights Law (NYSHRL): Discrimination and retaliation based on race and ethnicity.

• New York City Human Rights Law (NYCHRL): Broad anti-discrimination protections, including perceived political belief discrimination.

• New York Labor Law § 740 and Civil Service Law § 75-b: Retaliation for protected whistleblowing.

• Marijuana Regulation and Taxation Act (MRTA): Unlawful adverse employment action based solely on metabolite presence in the absence of impairment.

The charge further references , Inc., 22 N.Y.3d 1 (2013), in support of the claim that Psychemedics. However, a third party may be held liable under New York law for negligently issuing drug test results with disciplinary consequences.

Remedy Sought: Accountability and Structural Reform

Palaguachi seeks not only individual remedies—including back pay, reinstatement, and compensatory damages—but also institutional change. His complaint calls on the EEOC to investigate the NYPD’s drug testing program as a systemic violation of civil rights laws and to order comprehensive reforms, including:

• The suspension of hair-based drug testing until it is scientifically validated and free of racial bias.

• Implementation of procedural safeguards, including sample verification, DNA authentication, and appeal rights.

• Transparent auditing of testing outcomes by race, gender, and national origin, as required under UGESP.

• Disclosure of selection algorithms and documentation used in the random testing process.

• Public reporting of disciplinary outcomes to prevent selective enforcement and ensure accountability.

A Call to Action

“Too often, civil rights violations within law enforcement go unchallenged because of the blue wall of silence,” said Sanders. “But Officer Palaguachi is standing up—not just for himself, but for every officer who has been targeted, retaliated against, or silenced. This case is about justice, science, and the pursuit of fairness. And the law is on his side.”

The EEOC will now investigate the claims and may issue a determination. If the agency finds reasonable cause to believe discrimination occurred, it may initiate conciliation or issue a right-to-sue letter permitting civil litigation in federal court.

In the meantime, this case puts the NYPD and its private testing partner on notice: institutional discrimination and scientifically unsound policies will no longer go unchallenged.

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New York, N.Y. — Today, April 17, 2025, in a harrowing civil rights lawsuit filed in the United States District Court for the Eastern District of New York, Brooklyn resident Keyanna Moody, a Black mother and lawful e-bike operator, alleges she was violently assaulted, unlawfully arrested, racially abused, and denied medical care by members of the New York City Police Department (NYPD) on June 11, 2024. The federal complaint, filed under 42 U.S.C. § 1983 and the New York City Human Rights Law (NYCHRL), details a traumatic encounter that began with a routine family outing and ended in physical and psychological trauma.

The lawsuit names as defendants Lieutenant Daniel Lacalamita, Sergeant Stanislav Zubyk, Police Officers Michael R. Moran, Alvin M. Nieves, Jared W. Cordero, and John Does 1 through 5, as well as the City of New York. The Complaint asserts claims under the First, Fourth, and Fourteenth Amendments, including excessive force, false arrest, racial profiling, retaliation, denial of medical care, and Monell liability.

What Began as a Family Ride Ends in Brutality

According to the complaint, Moody and her husband began their evening ride at Canarsie Pier, each operating a street-legal electric bicycle. Moody rode a Z6 Fly E-Bike, while her husband rode a Venom Fly E-Bike—neither of which requires registration, licensing, or insurance under New York law. While at the pier, they encountered two other individuals on motorcycles, and the group decided to head to Coney Island together. The plan was simple: Moody wanted to buy cotton candy for their five-year-old daughter, while the others planned to stop at Nathan’s Famous.

As they traveled, Moody and her husband followed the designated bike paths, while the motorcyclists took the highway route. By approximately 9:05 P.M., after retrieving the cotton candy, the group reunited near Surf Avenue and West 15th Street in Coney Island, chatting and exchanging contact information before preparing to leave.

At that moment, multiple NYPD officers—some in an unmarked vehicle and others on a police scooter—suddenly surrounded them. As indicated in the complaint, the officers aggressively approached without warning or legal justification. Officer Nieves allegedly snatched the e-bike keys from Moody’s ignition and demanded her license and registration. The complaint asserts that Moody had violated no law, and she calmly explained that her vehicle did not require documentation. Nevertheless, Lieutenant Lacalamita, the highest-ranking officer present, ordered her arrest without probable cause.

Tackled, Tased, and Thrown Face-First into a Police Vehicle

The complaint paints a harrowing picture of escalating brutality. After allegedly ordering Moody’s arrest without probable cause, Lacalamita watched as Officers Moran and Cordero tackled her to the ground. Officer Nieves attempted to tase her multiple times; when unsuccessful, he joined in physically restraining her. As Moody lay prone and handcuffed on the pavement, Moran stepped on her back and legs, while Nieves dug his knee and hands into her spine.

The officers then allegedly forced her face-first into the backseat of a patrol vehicle. During this, her foot became trapped in the doorframe. She screamed in pain, but officers ignored her cries for help before finally releasing her foot.

Adding to the trauma, Lieutenant Lacalamita allegedly berated Moody with racial slurs—calling her a “Black bitch,” attempting to slap and kick her, and ordering officers to “put that bitch in a cage.” She was then placed into another patrol car equipped with a prisoner partition and transported to the 60th Precinct, where the abuse continued.

Still handcuffed, Moody was brought before an unidentified desk officer. There, Lieutenant Lacalamita allegedly kicked her to the floor and stood over her yelling, “Get the f* up**,” while none of the officers present intervened. Despite the presence of a female officer, male officers conducted a full-body search, allegedly making inappropriate contact with Moody’s breasts, buttocks, thighs, and vaginal area. Her repeated demands to know the charges against her were met with silence.

Denied Medical Care, Misled at the Hospital, and Deprived of Property

Despite visible injuries—bleeding knees, torn clothing, and a dirt-covered body—Moody was allegedly denied medical attention for over five hours while detained at the 60th Precinct. Her repeated pleas to Officers Nieves and Cordero were ignored. Only after she refused to provide fingerprints were paramedics finally summoned.

Moody was transported to South Shore Brooklyn Hospital, where EMTs performed only a cursory evaluation. While in the resuscitation area, Lieutenant Lacalamita allegedly reappeared, lied about his identity, stating “I’m not him. I wasn’t there,” and fled when confronted. According to the complaint, Dr. Spencer Doblin Kim, the attending physician, refused to examine her, withheld discharge paperwork, and handed the documents to the NYPD escort instead of giving them to Moody herself. She only discovered the doctor’s identity later via a MyChart notification.

After her release from the hospital, Moody was returned to the 60th Precinct and later transferred to Brooklyn Central Booking, where the District Attorney declined to prosecute her case. However, the ordeal did not end there. Despite her charges being dropped, NYPD officers refused to return her property—including her Z6 Fly e-bike, phone, jewelry, ID, keys, and cash—even after she presented a DA-issued property release form. Instead, she was allegedly told the form was “meaningless” and was threatened with arrest if she did not leave the precinct.

A Pattern of Institutional Failure

The federal complaint does not isolate misconduct to a few rogue actors—it exposes systemic failures within the New York City Police Department in training, supervising, and disciplining officers with well-documented records of abuse. Each of the named officers in the lawsuit—Lieutenant Lacalamita, Sergeant Zubyk, and Officers Moran, Nieves, and Cordero—has been previously implicated in allegations of misconduct. Yet, the City of New York has continued to employ and promote them, emboldening unconstitutional policing.

• Lieutenant , who allegedly directed and physically participated in the violent arrest of Keyanna Moody, has faced multiple CCRB complaints in past years, including allegations of abuse of authority and excessive force. The complaint states that Lacalamita’s use of racial slurs, physical violence, and retaliatory threats against Moody highlights a longstanding pattern of misconduct, exacerbated by the NYPD’s refusal to hold him accountable.

• Sergeant allegedly stood by as a supervisor, watching the illegal arrest and use of force unfold without taking action. According to the lawsuit, Zubyk’s inaction reflects not only personal indifference but also a broader NYPD failure to empower supervisors to prevent or report unlawful conduct.

• Officer , accused of initiating the stop by allegedly seizing Moody’s e-bike keys illegally, has a documented history of civil rights complaints, including alleged unlawful stops and unreasonable searches. The lawsuit states that Nieves attempted to tase Moody multiple times and later participated in violently restraining her, even as she screamed in pain with her foot caught in the patrol car door.

• Officer is alleged to have stepped on Moody’s legs and shoved her into a police vehicle, later participating in a full-body search by male officers despite the presence of a female colleague. Past CCRB records cite Moran for use of force and discourtesy, and the complaint argues that his behavior toward Moody is part of a pattern of racial and gender-based abuse.

• Officer is accused of violently tackling Moody to the ground, ignoring her requests for medical care, and refusing to return her property even after she obtained a DA-issued release form. The lawsuit contends that Cordero’s conduct shows deliberate indifference to both constitutional rights and human dignity.

Despite these officers’ disciplinary histories and prior complaints, the City of New York continues to place them in active field roles, with supervisory backing. The lawsuit alleges that the NYPD has repeatedly ignored red flags, failed to remove problem officers, and allowed racial and gender bias to flourish unchecked.

This institutional failure, the complaint contends, is what made the violent and baseless arrest of Keyanna Moody not only possible but predictable.

A Pattern of Abuse: NYPD’s Troubling History of Civil Rights Violations

The misconduct alleged in Moody’s federal complaint is not an aberration—it reflects a deeply entrenched pattern of unconstitutional policing long associated with the New York City Police Department (NYPD). For decades, civil rights attorneys, independent monitors, and oversight bodies have documented pervasive problems involving racial profiling, excessive force, retaliatory arrests, denial of medical care, and unlawful stops, particularly targeting communities of color.

Ms. Moody’s experience—being tackled to the ground, called a racial slur, handcuffed, physically abused, denied medical care, and detained without cause—is emblematic of the broader institutional culture that the lawsuit seeks to expose. Her case follows a well-documented history in which Black and Latino New Yorkers are disproportionately targeted, with little to no accountability for officers who engage in misconduct.

This complaint does not merely assert individual wrongdoing. It highlights a systemic failure of supervision, training, and accountability, alleging that the City of New York has knowingly allowed officers with documented misconduct histories to continue policing without intervention, discipline, or retraining.

Notable Parallel Cases of NYPD Misconduct

The experiences described in Moody’s lawsuit mirror other high-profile NYPD misconduct cases that have drawn national attention:

• Eric Garner (2014): Died after being placed in a banned chokehold by Officer Daniel Pantaleo while under arrest for allegedly selling untaxed cigarettes. The incident, captured on video as Garner repeatedly said “I can’t breathe,” triggered national protests. The City paid $5.9 million in a wrongful death settlement.

• Delrawn Small (2016): Shot and killed in a Brooklyn road rage incident by off-duty Officer Wayne Isaacs within seconds of approaching Isaacs’ vehicle. Video evidence contradicted Isaacs’ self-defense claims. Although acquitted at trial, the case raised questions about internal NYPD discipline and prosecutorial accountability.

• Kawaski Trawick (2019): Shot inside his own Bronx apartment by officers who entered without a warrant. Trawick was not a threat, and yet no meaningful discipline was imposed, raising concerns about NYPD responses to mental health crises and officer accountability.

• Dounya Zayer (2020): Thrown to the ground by an NYPD officer during a protest in Brooklyn, suffering a traumatic brain injury. The incident was recorded and widely shared, prompting over 60 disciplinary findings against NYPD personnel for misconduct related to protests.

These incidents—like Moody’s—are not outliers. They are part of a systemic failure to uphold constitutional protections. In each case, officers acted outside department policy or legal limits, and supervisory failures allowed the misconduct to go unchecked.

NYPD Oversight Data Corroborates Systemic Abuse

The lawsuit draws on the findings of the —published as part of ongoing federal oversight under the Floyd v. City of New York litigation—to contextualize Ms. Moody’s experience. Among the report’s key findings:

• Black New Yorkers accounted for 29.8% of all NYPD vehicle stops in Q4 2024, despite comprising only 22.7% of the City’s population;

• White residents, who make up 35.9% of the population, were stopped only 17.8% of the time;

• Neighborhood Safety Teams (NSTs) engaged in unconstitutional stops more than 25% of the time;

• Supervisors approved 99.1% of all stop reports, regardless of their legality.

Moody’s encounter—initiated over an e-bike that did not legally require documentation—fits this pattern precisely. Her stop was not supported by probable cause, and her attempts to calmly assert her rights were met with retaliation, racial hostility, and force. The failure to discipline involved officers, despite clear violations of NYPD policies, reinforces the systemic failures identified in the Floyd Monitor’s review.

Legal Claims and Relief Sought

Moody’s federal lawsuit brings claims under the:

• First Amendment (retaliation for asserting legal rights),

• Fourth Amendment (unlawful seizure, excessive force),

• Fourteenth Amendment (due process, equal protection, denial of medical care),

• 42 U.S.C. § 1983 (civil rights violations),

• New York City Human Rights Law (NYCHRL) § 8-107(17) (racial profiling and discriminatory policing), and

• Monell liability against the City of New York for failing to train, supervise, and discipline officers.

She seeks compensatory damages, punitive damages, declaratory relief, and attorneys’ fees and costs.

Eric Sanders: “We Will Not Be Silent”

Eric Sanders, Esq., of ¸ŁŔűź§., who represents Ms. Moody, issued the following statement:

“What happened to Mrs. Moody is disgraceful. For doing nothing more than purchasing cotton candy for her child, she was dehumanized, brutalized, and unlawfully imprisoned by NYPD officers who acted with impunity. This lawsuit isn’t just about seeking justice for her—it’s about exposing the systemic rot that continues to define policing in communities of color. We demand accountability. We demand change.”

Contact:

For media inquiries, legal commentary, or to support Mr. Ryan’s case, contact:

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30 Wall Street, 8th Floor
New York, NY 10005
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Read the Federal Complaint

The post “Put That Bitch in a Cage”: Federal Lawsuit Accuses NYPD of Racist Abuse and Brutal Arrest in Brooklyn first appeared on ¸ŁŔűź§..