UNITED STATES DISTRICT COURT, SOUTHERN DISTRICT OF OHIO 

EASTERN DIVISION 

STORMY BLANKINSHIP : 

1592 BUTTERFLY COURT 

COLUMBUS, OHIO 43223 : 

 PLAINTIFF, : 

 CASE NO. 

 : 

 JUDGE 

 : 

 MAGISTRATE JUDGE 

 : 

v. COMPLAINT 

 : 

JURY DEMAND ENDORSED

 : HEREON

SEQUEL YOUTH AND FAMILY 

 SERVICES : 

1131 EAGLETREE LANE 

HUNTSVILLE, ALABAMA 35801 : 

 

 DEFENDANT. 

 

PARTIES

Plaintiff, Stormy Blankinship, complaining of Defendant alleges as follows: 

1. Plaintiff is an individual citizen of the State of Ohio. 

 2. Defendant is an Alabama corporation with an office located at 765 

Pierce Road, Columbus, Ohio, Franklin County. 

 3. The acts complained of herein took place in Franklin County, Ohio. 

 4. Plaintiff was employed with Defendant from March 2016 to March 

2, 2017 as a Licensed Practical Nurse. 

JURISDICTION AND VENUE

5. Jurisdiction is based upon 28 USC §1332 because the action

involves citizens of separate states and the matter in controversy exceeds the 

sum of seventy five thousand dollars ($75,000.00). 

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6. Venue lies in the Southern District of Ohio pursuant to 28 U.S.C. 

§1391 based upon the illegal acts of Defendants which occurred in the County of 

Franklin, State of Ohio. 

FIRST CLAIM FOR RELIEF: 

WRONGFUL DISCHARGE IN VIOLATION OF PUBLIC POLICY AND OHIO 

COMMON LAW

 7. The allegations of the prior paragraphs are incorporated as if fully 

set forth below. 

 8. Among other public policies, Ohio has a public policy through 

statutes, regulations and common law against taking adverse employment 

action, including termination of employees who refuse to refrain from reporting 

abuse and/or neglect of juvenile residents and reporting staff nursing shortages 

of care facilities. 

 9. Defendant has violated these public policies. 

 10. Plaintiff was ordered to participate in the public policy violations 

described above. 

 11. Plaintiff refused to participate in the aforementioned public policy 

violations and as a result of said refusals, she was terminated. 

 12. Defendants’ termination of Plaintiff was unlawful. 

 13. As a direct and proximate result of Defendants’ conduct as set forth 

above, Plaintiff has suffered loss of compensation, loss of fringe benefits, loss of 

the opportunity to be able to continue the gainful employment in which she has 

been engaged previously, loss of future earnings, loss of future earning capacity 

and loss of reputation, humiliation, embarrassment, loss of self esteem, other 

emotional distress, adverse health, and loss of time and money endeavoring to 

protect herself from Defendants’ unlawful discrimination, including costs, expert’s 

fees, attorney’s fees and interest. 

 

THIRD CLAIM FOR RELIEF: VIOLATION OF ORC §3721.24

 14. The allegations of the prior paragraphs are incorporated as if fully 

set forth below. 

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 15. The Plaintiff reported abuse or neglect of its juvenile residents 

and/or indicated an intention to make such a report and/or provided information 

during an investigation of suspected abuse and/or neglect. 

16. Defendant took adverse action against Plaintiff for making the 

reports, including terminating her employment. 

17. Defendant’s adverse action was taken in violation of ORC 

§3721.24. 

 18. As a direct and proximate result of Defendant’s conduct as set forth 

above, Plaintiff has suffered loss of compensation, loss of fringe benefits, loss of 

the opportunity to be able to continue the gainful employment in which she has 

been engaged previously, loss of future earnings, future earning capacity and 

loss of reputation, humiliation, embarrassment, loss of self esteem, adverse 

health, emotional distress, and loss of time and money endeavoring to protect 

herself from Defendant’s unlawful conduct, including costs, expert’s fees, 

attorney’s fees and interest. 

WHEREFORE, Plaintiff prays as to Defendant as follows: 

(a) That this Court award such equitable relief as is proper as 

compensation for the loss of opportunity to engage in gainful 

employment, including relief in the form of front pay and benefits or 

reinstatement; 

 

(b) That this Court award Plaintiff compensation for her adverse health 

effects, for the loss of his opportunity to engage in gainful 

employment, and future earnings, lost earning capacity and for 

humiliation, embarrassment, loss of reputation, loss of self-esteem, 

adverse health and for emotional distress; 

(c) That this Court award Plaintiff all lost wages and benefits; 

 

 (d) That this Court award Plaintiff punitive damages; 

 

(e) That this Court award Plaintiff reasonable attorney’s fees, expert 

fees, expenses and the costs of this action; 

(f) That this Court award Plaintiff liquidated damages; 

(g) That this Court award Plaintiff interest and prejudgment interest; 

and 

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(h) That this Court grant Plaintiff such other and further relief as may 

be just and equitable. 

 Respectfully Submitted, 

 /s/Rayl L. Stepter

 Rayl L. Stepter (0047505) 

 5650 Paul Blazer Parkway 

 Dublin, Ohio 43017 

 (614) 468-4100 

 (614) 468-4101 (Fax) 

 raylstepter@stepterlaw.com 

 Trial Attorney for Plaintiff 

Plaintiff demands trial by jury. 

 

 /s/Rayl L. Stepter

 Rayl L. Stepter 

 Trial Attorney for Plaintiff 

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