IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHISN DISTRICT OF ILLINOIS

EASTERN DIVISION

ANTHONY J. SINNOTT, )

)

Plaintiff, )

)

v. ) Case No.

)

CICERO POLICE DEPARTMENT )

AND THE CITY OF CICERO, ) JURY TRIAL DEMANDED

)

Defendant. )

COMPLAINT

NOW COMES Plaintiff, ANTHONY SINNOTT (“SINNOTT”), by and through his 

attorneys, TRENT LAW FIRM, P.C., complaining against the Defendants in this matter, CICERO 

POLICE DEPARTMENT and TOWN OF CICERO (hereinafter collectively “CICERO” or 

“Defendants”), states as follows:

NATURE OF THE ACTION

This is an action for injunctive relief and for damages against the defendants to enforce the 

Plaintiff’s rights secured by Title VII of the Civil Rights Act of 1964, as amended (42 U.S.C. § 

2000e et seq.) (“Title VII”) and for state law causes of action.

PARTIES

1. Plaintiff SINNOTT is an adult, African American, male citizen who resides within 

the territorial jurisdiction of the District Court.

2. CICERO is an Illinois Municipal Corporation and/or Township Corporation, with 

its principal place of business in Cicero, Cook County, Illinois.

3. The Town of CICERO operates the Cicero Police Department.

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4. At all relative times, CICERO employed more than fifteen (15) employees and was 

Plaintiff’s employer.

5. CICERO, at all times relevant to this Complaint, operated within the territorial 

jurisdiction of the District Court.

JURISDICTION

4. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. §§ 1331 and 1343, as 

the district courts have original jurisdiction of all civil actions arising under the Constitution, laws, 

or treaties of the United States, and its supplemental jurisdiction over the state claims under 28 

U.S.C. § 1367.

5. Jurisdiction is invoked pursuant to 42 U.S.C. § 1981 including 42 U.S.C. § 

1981a(c)(2) (limits do not apply to back pay or front pay, which is awarded under 42 U.S.C. § 

2000e5(g)(1)).

6. All jurisdictional prerequisites to a lawsuit have been met to wit:

a. On February 25, 2019, Plaintiff filed a charge of discrimination alleging 

discrimination based on race and retaliation which was perfected by the Illinois Department 

of Human Rights (“IDHR”) and by a work sharing agreement between the Department and 

the Equal Employment Opportunity Commission (“EEOC”) was cross-filed and perfected 

at both agencies;

b. The charge was filed at the IDHR (see Exhibit A);

c. The charge was perfected by the IDHR and thus was perfected at both the 

IDHR and the EEOC (see Exhibit A);

d. The charge was assigned EEOC Charge No. 2019 CR 3121;

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e. The charge pursuant to the work-sharing agreement between agencies was 

filed within 300 days of the date of the last act of discrimination, retaliation and harassment, 

which was and were on-going through the date Plaintiff’s employment was terminated;

f. Plaintiff received a Right-to-Sue letter from the EEOC dated December 20, 

2019 (see Exhibit B);

g. This lawsuit is being filed within 90 days of the date of receipt of the Rightto-Sue letter (see Exhibit B);

7. Plaintiff is raising claims that all flow out of a common nucleus of common facts 

and parties.

VENUE

8. Venue is proper in this district pursuant to 28 U.S.C. § 1391(b), because:

a. Defendant CICERO, is a municipality in this court’s jurisdictional district; 

and

b. all events or omissions giving rise to Plaintiff’s claims occurred here in this 

jurisdictional district.

FACTS

9. Defendants are local governmental entities, are and were, at all times relevant, 

“employers” and/or “covered entities” within the meaning of Title VII of the Civil Rights Act of 

1964.

10. That SINNOTT began his police career in 2008 when he was hired by the Harvey 

Police Department on August 25. 

11. That SINNOTT served the community of Harvey for approximately nine years and 

obtained the civil service rank of Sergeant. 

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12. That SINNOTT was one of the youngest patrol officers in the history of the Harvey 

Police Department to earn the civil service rank of patrol sergeant via state sanctioned testing. 

13. That SINNOTT was awarded multiple service awards, accommodations, lifesaving 

awards, shift awards and numerous community recognitions. 

14. That, in pertinent part, these awards included four lifesaving awards, a service 

award for participation in the Harvey Hostage Standoff, numerous shift of the month awards, a 

service award for aiding in the capture and arrest of four homicide suspects who were wanted in 

the State of Georgia, community service awards, and several mentions from Restoration 

Ministries. 

15. SINNOTT also obtained numerous training certifications to include, but not limited 

to, first line supervisor, hundreds of hours in patrol rifle tactics and training, leadership training, 

community policing objectives and tactics, gang enforcement, rapid deployment and response, 

mass casualty aid and response, active shooter, response and planning for bomb and explosive 

threats, tactical medicine and care under fire. 

16. On January 1, 2017, SINNOTT left the Harvey Police Department and continued 

his career with CICERO. 

17. CICERO hired SINNOTT on or about January 1, 2017 to work as a full-time, sworn 

police officer for the Town of Cicero Police Department.

18. That upon information and belief, SINNOTT was the only African American male 

hired by CICERO since 2014.

19. That upon information and belief, SINNOTT was the last police officer of African 

American descent that has been hired by CICERO.

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20. That during the course of his employment with CICERO, SINNOTT brought real 

world experience, seasoned investigative skills, and a comprehensive community policing outlook. 

21. That upon information and belief, CICERO’S administration is comprised 

predominantly of Caucasian males.

22. Deputy Superintendent Boyle (“BOYLE”), Caucasian, is the Deputy 

Superintendent for CICERO.

23. Commander Polk (“POLK”), Caucasian, is a Commander for CICERO.

24. Captain Flores (“FLORES”), Hispanic, is a Captain for CICERO.

25. Sergeant Skrabacz (“SKRABACZ”), Caucasian, is a Sergeant for CICERO.

26. Commander Vincent Acevez (“ACEVEZ”), Caucasian, was a Commander who 

was then promoted Deputy Superintendent of Patrol.

27. Sergeant Rowe (“ROWE”), African American, is a Sergeant with CICERO.

28. That SINNOTT was assigned a defective radio with serial number #B4A00068 and 

a locator assigned to another officer. 

29. That SINNOTT was also assigned a battery serial #0215C00160 that did not 

function properly. 

30. That due to the defective radio, SINNOTT would have to constantly reference the 

dispatch center with a call of 10-97 which is a radio check for signal clarity over the main radio 

channel to make sure his two-way radio was functioning properly. 

31. That on numerous occasions, SINNOTT would get a call back of 10-1 meaning 

unable to copy or weak signal from the dispatchers and SINNOTT would then have to reset his

radio. 

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32. That after adjusting the radio, SINNOTT would attempt another 10-97 over the air 

until he received a 10-2 response meaning that his signal was good. 

33. That SINNOTT continuously had to perform these radio actions between 

approximately January 1, 2017 to June 11, 2018 and, upon information and belief, other nonAfrican American officers did not have to perform these actions.

34. That once the defective radio and battery were discovered, SINNOTT notified 

SKRABACZ during his first phase of field training. 

35. That due to the defective radio, SINNOTT would have to constantly reference the 

dispatch center with a call of 10-97 which is a radio check for signal clarity over the main radio 

channel to make sure his two-way radio was functioning properly. 

36. SINNOTT later explained that the battery SINNOTT was issued was defective and 

gave no audible signal indicating its charge status.

37. The battery would die between 15 percent and 12 percent.

38. SINNOTT was written up on April 27, 2018, as a result of being issued defective 

equipment by FLORES.

39. That SINNOTT was hired with other officers to include, without limitation, Officer 

Smith, Caucasian, Officer Cuchna, Caucasian, Officer Jimenez, Hispanic, and Officer Bello, 

Hispanic, and these non-African American officers received properly functioning equipment.

40. SINNOTT was forced to shave his face with a razor after advising CICERO that he 

couldn’t. 

41. As a result, SINNOTT had to obtain a written prescription to remedy his condition

from a doctor to provide to CICERO.

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42. That SINNOTT consulted with Dr. Manuel S. Mesirow, M.D. who issued a 

prescription and remedy for SINNOTT’S skin condition. 

43. SINNOTT was subjected to hostile work environment as a result of his skin color.

44. That SINNOTT suffers from Pseudofolliculitis Barbae which is a common, 

chronic, inflammatory skin condition that occurs as a result of shaving and affects mainly men of 

African descent. 

45. That SINNOTT advised CICERO that he is unable to shave with a razor due to his 

medical condition. 

46. That CICERO forced SINNOTT to shave with a razor even after SINNOTT advised 

CICERO that he could not. 

47. That SINNOTT was continually scrutinized and criticized by non-African 

American command staff.

48. That in December 2017, POLK would make comments to SINNOTT regarding his 

skin being dark and bumpy. 

49. That POLK also compared the African American officer’s skin tone to the color 

and texture of a brown paper bag during roll call in the early winter of 2018. 

50. That ROWE was present and complained to the administration, including FLORES 

and BOYLE, about the comments that were made, and, upon information and belief, no 

disciplinary action was taken against POLK. 

51. That SKRABACZ and FLORES constantly requested SINNOTT to shave his face 

after he submitted a prescription from his dermatologist and appropriate paperwork.

52. That after notifying CICERO of his medical condition, SINNOTT was assigned to 

vehicles that were mechanically not safe to drive and had faulty electronics. 

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53. That these vehicles needed suspension replacement, tire replacement, windshield 

replacement, electronic maintenance for the mobile computer systems, emergency equipment had 

intermittent faults and the vehicle had numerous service lights illuminated on the dashboard. 

54. SINNOTT was assigned marked patrol vehicle 318, which was not mechanically 

sound, nor did the electronics operate properly. 

55. Additionally, the vehicle GPS system had a general malfunction as it would not 

accurately depict the location of this vehicle.

56. The vehicle should have been removed from active status for repair.

57. All service lights were illuminated on the vehicle dashboard (traction control, 

service engine soon, abs light and airbag light), mobile computer system would turn off after 

approximately three minutes of idle time, emergency equipment had an intermittent short as the 

lights and sirens wouldn’t always function when activated.

58. SINNOTT was written up for incident 201800034994 and 201800034995 as a 

result of having to use defective equipment.

59. SINNOTT was advised by SKRABACZ that the vehicle GPS system showed the 

patrol vehicle positioned at the Cicero Police Facility during the incident.

60. SINNOTT advised that he was in fact not at the police facility for a few hours

despite the vehicle’s GPS indicating that he was.

61. SKRABACZ then proceeded to accuse SINNOTT of tampering with the GPS

system which is protected by multiple administrative passwords.

62. SINNOTT has no knowledge of the inner workings of the system, nor did he tamper 

with the system.

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63. During this event, BOYLE stated that vehicle 318 was properly serviced and 

functioning as it should.

64. That SINNOTT was then falsely accused of damaging a vehicle without a proper 

investigation being completed by POLK and BOYLE. 

65. There were small dents on the vehicle, which had been documented as previous 

damage to the unit.

66. SINNOTT was ordered to submit a communication memo regarding the incident 

on May 9, 2018.

67. SINNOTT advised of the stated information and gave his location of 1500 S. 54th

Ave., Cicero, IL 60804.

68. SINNOTT was later approached by SKRABACZ on May 10, 2018, who requested 

that SINNOTT submit another communication memo regarding the same event but to change the 

location to reflect the Police Department.

69. SKRABACZ stated that he had lost the original copy SINNOTT submitted to him.

70. On May 15, 2018, SINNOTT submitted another memo, identical to his previous

memo without making the recommended change of location.

71. SKRABACZ attempted to have SINNOTT falsify the facts of the event so that he 

could generate a disciplinary action against SINNOTT.

72. SINNOTT’s refusal to falsify the location of his squad car during the above 

incident, at SKRABACZ’s behest, resulted in a disciplinary action which BOYLE used to 

terminate SINNOTT’s employment.

73. CICERO did not conduct a proper investigation, nor provide SINNOTT with an 

interview, nor progressive discipline as outlined in the CICERO Employee Handbook, CICERO 

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Rules and Regulations of Board of Police, Fire and Public Safety, nor the Collective Bargaining 

Agreement.

74. That on August 28, 2018, Plaintiff filed charges with the Illinois Department of 

Human Resources (“IDHR”) for the racial discrimination he was being subjected to at CICERO 

(see Exhibit A).

75. That while in field training and on probation, SINNOTT was subjected to a 

productivity system, also known as a matrix system (“Matrix”). 

76. SINNOTT was always within the standard related to the Matrix as described in the 

Cicero Police Department’s General Orders. 

77. That the Matrix was used to track activity that was assigned a points value per 

section or action taken such as Calls For Service, IVC Misdemeanor Arrests/ Warrant Packet, 

MISD Arrests- (non-IVC), Felony Arrests, Quasi Arrests, Warrant Arrests (All/ regardless of 

classification), Y Citations, AO Tickets, Street Stops w/ Field Contact Cards of P.S.C., Recovered 

Guns, Reports- GRF/ Supplemental/ CRASH, Parking Citations, Details/ Maj. Inc Scene- #of 1 

hr. segments, Vehicle Impounds and Walk & Talks/ Business Checks. 

78. That the Matrix was also used to create means of discipline.

79. That during evaluations, SKRABACZ and FLORES would make comments to 

SINNOTT such as “your numbers aren’t high enough” and “Be careful you won’t make it.” 

80. That these comments and statements were referencing discipline and being placed 

on a probationary system regarding productivity due to the Matrix. 

81. That upon information and belief, this probation was issued mainly to African 

American employees including Officer Paul Laslie, Officer Amilcar, and SINNOTT as a method 

of harassment. 

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82. That there were multiple occasions when SINNOTT was approached by nonAfrican American supervisors including POLK, FLORES, BOYLE and SKRABACZ whereby 

they threatened discipline as a result of the Matrix.

83. That on January 12, 2018, ROWE called SINNOTT and stated to him, “Young 

man, make sure you watch yourself around here. They don’t like you and feel you are a threat. 

The history and culture of this place is not pro us. Boyle has Commander Polk watching you along 

with Scribbles (SKRABACZ). He tried to write you up for your hair claiming he doesn’t have 

your papers.” 

84. That upon information and belief, SINNOTT’S paperwork would continuously be 

misplaced by command staff which included SKRABACZ, POLK, FLORES and BOYLE. 

85. That SINNOTT submitted approximately eight copies of his medical documents 

during his period of employment. 

86. In July of 2017, SINNOTT was approached by SKRABACZ regarding a Town of 

Cicero Voters Alliance golf outing ticket.

87. SKRABACZ stated that SINNOTT should purchase the ticket because he is on 

probation and the odd man out meaning he is African American.

88. SINNOTT refused the purchase as the activity violated his moral standards which 

he believed included drinking, smoking and patronizing female escorts.

89. SINNOTT was the only officer from the group of probationary employees all being 

Caucasian and Hispanic that did not purchase a ticket.

90. SINNOTT’S name was then later discovered on a list located on the Sergeant’s 

desk area in patrol around early August of 2017 noting all personnel that did not purchase golf 

outing tickets.

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91. The list also named ROWE’s and Officer Kelley’s, both African Americans, and 

Lenni Rizzi’s (“RIZZI”), Caucasian).

92. RIZZI is not associated with the command staff nor political bodies within the 

Town of Cicero and, upon information and belief, openly speaks out against the inequities 

displayed in the department. 

93. On or about March of 2018, POLK approached SINNOTT in an aggressive 

demeanor, stopping very close to SINNOTT’s face and speaking with a raised voice regarding a 

court case stemming from SINNOTT’s previous employment with the Harvey Police Department, 

Carlos Fisher v. Det. Ostrowski (search warrant 8715B-12).

94. Gregory E. Kulis and Assoc. Ltd. (“KULIS”) contacted CICERO regarding a court 

case Fisher v. Ostrowski (search warrant 8715B-12).

95. SINNOTT complied with the court proceedings and provided CICERO with 

documents related to the case.

96. The case file contained all completed reports, supplemental reports, inventory 

documents and a daily assignment card (day off) for the day of work related to the incident. 

97. SINNOTT further explained to POLK and BOYLE multiple times that there was a 

mistake made and SINNOTT was not present for the incident nor at work that day.

98. The daily assignment card clearly depicted the staff for the day. POLK accepted 

the paperwork from SINNOTT near the employee entrance of the Cicero Police Department while 

walking into the roll call room (recorder area).

99. Later, in April of 2018, approximately April 24, 2018, BOYLE approached and 

ordered SINNOTT to comply with the court proceedings.

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100. As SINNOTT attempted to explain the situation and provide another copy of the 

documents, BOYLE stated, “I don’t want anything from you, just do as I say!” The Deputy then 

walked away from the area.

101. The command staff including POLK and BOYLE continued to pursue disciplinary 

action against SINNOTT.

102. BOYLE blatantly disregarded facts in order to create a discipline opportunity and 

openly stated he had a dislike towards SINNOTT because of his appearance and personality. 

103. BOYLE was provided with emails from Harvey’s municipal Counsel, Seth J. Levin 

of Smith Amundsen LLC stating that SINNOTT was not named in the lawsuit and should not be 

held responsible for KULIS’ actions.

104. KULIS continued to contact the CICERO after SINNOTT’s separation from 

employment. 

105. The last date of contact was June 30, 2018 when KULIS again, attempted to deliver 

a subpoena for James A. Sinnott to the Cicero Police Department.

106. It was found that KULIS continued to contact CICERO regarding a court case 

Fisher v. Ostrowski (search warrant 8715B-12). 

107. KULIS allegedly provided false information to CICERO resulting in a one-sided 

disciplinary action against SINNOTT by BOYLE and POLK.

108. Upon information and belief, KULIS created a document stating that SINNOTT 

would be issued a warrant for failure to comply with court proceedings.

109. Upon information and belief, that document was sent to the CICERO after 

SINNOTT attempted to comply with the first subpoena that was issued from KULIS’ office.

110. That BOYLE stated, “the Town should never hire y’all.” 

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111. That, upon information and belief, BOYLE always had heated or tense interactions 

with employees of African American descent.

112. SINNOTT was subjected to harsher work conditions and given assignments that 

Caucasian or Hispanic officers would not be assigned.

113. SKRABACZ, POLK and FLORES would assign “Special Details” to SINNOTT, 

which would take him away from his regular duties.

114. They would then create a discipline report stating that SINNOTT was neglecting 

his other duties as a result of fulfilling the assignment.

115. These assignments would consist of directed patrol in specific areas of the town.

116. Most of these patrols would be in segments of the Town of Cicero that were 

occupied by residents of African American descent (Districts 1, 2 and 4). 

117. SINNOTT would also be assigned to traffic enforcement in a specified region of 

the City. 

118. After completing the assignment as ordered, SINNOTT would then be counseled 

by shift staff including FLORES, SKRABACZ, POLK, and ROWE. 

119. The counseling would be directed towards neglecting other areas of daily 

productivity as a result of the assignment. 

120. SINNOTT was frequently assigned traffic enforcement on Cicero Avenue. 

121. Multiple times, SINNOTT would issue numerous citations related to a variety of 

traffic infractions. 

122. Upon returning to the station, SINNOTT would be talked to and harassed regarding 

not having contact cards, pedestrian contact cards, business checks and arrests. 

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123. These actions were then included in SINNOTT’s personnel file as memos created 

by the staff including FLORES, SKRABACZ, POLK, and ROWE and never officially presented 

as discipline before being added to the personnel file. 

124. On May 7, 2018, ROWE texted SINNOTT to “meet me at the station.” 

125. ROWE stated, “I just wanted to stay out of the way and not have to deal with this.” 

126. He then advised SINNOTT that he was forced to follow the directives of POLK

and FLORES.

127. ROWE also advised that he was a victim of the racially driven inequities within the 

Cicero Police Department.

128. ROWE further related that POLK advised ROWE “smile so I can see you” while 

driving by a traffic stop on July 6, 2004 at 0250 hours.

129. POLK was allegedly disciplined by BOYLE, but a formal investigation never came 

about.

130. SINNOTT was written up for reporting to the shift late. 

131. SINNOTT arrived at 0045 hours after contacting ROWE.

132. SINNOTT was later advised by ROWE that he was ordered to complete a 

disciplinary action regarding SINNOTT’s tardiness by BOYLE.

133. SINNOTT had been tardy this one time throughout his employment with CICERO.

134. This discipline was not equally enforced as multiple Caucasian and Hispanic 

officers reported for duty after their scheduled time and were never disciplined.

135. On May 13, 2018, for example, Officer Ramos (“RAMOS”), Hispanic, reported for 

the shift late.

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136. After calling RAMOS’ cellular phone multiple times, he was finally contacted and 

stated he had overslept.

137. RAMOS was never disciplined for arriving late.

138. RAMOS arrived approximately an hour and a half late for his assigned shift (0015 

hours).

139. African American employees were held to a higher standard during uniform 

inspections.

140. African American employees were scrutinized because of having legitimate shave 

profiles during inspection.

141. Officers of Hispanic and Caucasian descent were not questioned nor harassed about 

their beards, appearance or status of their profiles.

142. Multiple Hispanic employees had beards while employed by the Cicero Police 

Department including, without limitation, Officer Alba and Officer Esparza.

143. That upon information and belief, the discipline was recommended by BOYLE.

144. Frequently, upon information and belief, SKRABACZ reported for duty and 

remained on duty while intoxicated.

145. For example, SKRABACZ was observed on duty while intoxicated on the 

following dates: April 27, 2018, May 9, 2018, May 7, 2018, May 15, 2018, and May 15, 2018, 

and was not fit to work. 

146. On June 11, 2018, at approximately 2315 hours, BOYLE, along with POLK, 

provided a letter stating that SINNOTT’s employment was terminated, without legitimate cause 

or reason.

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147. After BOYLE turned over the letter at approximately 2320 hours in the conference 

room located on the second floor of the police facility, BOYLE stated “Blacks don’t fit our police 

culture here.”

148. After the comment was made by BOYLE, BOYLE and POLK both had smirks on 

their face as SINNOTT exited the room to avoid any further conflict.

149. That on June 11, 2018, Plaintiff’s employment as a police officer with CICERO 

was terminated without legitimate cause or reason.

150. SINNOTT’S termination was pretextual and in retaliation for SINNOTT’S 

opposition to CICERO’S actions described above.

COUNT I

Title VII Race Discrimination

151. Plaintiff restates and realleges paragraphs 1-150 as if specifically set forth herein.

152. 42 U.S.C. § 2000e-2(a) makes it unlawful for an employer to discriminate against 

an employee on the basis of race.

153. Defendant violated 42 U.S.C. § 2000e-2(a) by treating SINNOTT differently than 

similarly-situated Caucasian and Hispanic employees because of his race.

WHEREFORE, Plaintiff respectfully requests that the Court:

A. Find that CICERO discriminated against Plaintiff, in violation of Title VII of the 

Civil Rights Act of 1964;

B. Award compensatory and punitive damages to the maximum amount provided by 

statute;

C. Award all back pay lost since the date of termination plus pre-judgment interest;

D. Award attorney’s fees, expert witness fees, and costs as provided by law;

E. Award forward pay due to decrease in earnings;

F. Retain jurisdiction over this action to assure full compliance with the order of this 

Court and with applicable law; and

G. Grant such additional relief as this Court deems just and proper.

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COUNT II

Title VII Race Harassment – Hostile Work Environment

154. Plaintiff restates and realleges paragraphs 1-153 as if specifically set forth herein.

155. 42 U.S.C. § 2000e-2(a) makes it unlawful for an employer to discriminate against 

an employee on the basis of race and affords employees the right to work in an environment free 

from discriminatory intimidation, ridicule, and insult.

156. SINNOTT belongs to a protected group. 

157. SINNOTT was repeatedly subjected to unwanted harassment based on his race as 

set forth above. 

158. CICERO knew and/or should have known of the harassment and failed to take 

prompt remedial action. 

159. At all times hereto, SINNOTT acted reasonably under the circumstances. 

160. CICERO is liable for the racial harassment due to a hostile work environment 

inflicted upon SINNOTT due to CICERO’S violation of Title VII of the Civil Rights Act of 1964

as set forth above.

WHEREFORE, Plaintiff respectfully requests that the Court:

A. Find that CICERO discriminated against Plaintiff, in violation of Title VII of the 

Civil Rights Act of 1964;

B. Award compensatory and punitive damages to the maximum amount provided by 

statute;

C. Award all back pay lost since the date of termination plus pre-judgment interest;

D. Award attorney’s fees, expert witness fees, and costs as provided by law;

E. Award forward pay due to decrease in earnings;

F. Retain jurisdiction over this action to assure full compliance with the order of this 

Court and with applicable law; and

G. Grant such additional relief as this Court deems just and proper.

COUNT III

TITLE VII Retaliation

161. Plaintiff restates and realleges paragraphs 1-160 as if specifically set forth herein.

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162. 42 U.S.C. § 2000e-3(a) makes it unlawful for an employer to discriminate against 

an employee because he opposes any practice which is unlawful under Title VII.

163. SINNOTT’S opposition to CICERO’S actions described above, is protected under 

42 U.S.C. § 2000e-3(a).

164. CICERO terminated SINNOTT’S employment in retaliation for his protected 

conduct.

WHEREFORE, Plaintiff respectfully requests that the Court:

A. Find that Defendant CICERO discriminated against Plaintiff, in violation of Title 

VII of the Civil Rights Act of 1964 and 29 C.F.R. § 1604.11(a);

B. Award compensatory and punitive damages to the maximum amount provided by 

statute;

C. Award all back pay lost since the date of termination plus pre-judgment interest;

D. Award attorney’s fees, expert witness fees, and costs as provided by law;

E. Award forward pay due to decrease in lower earnings;

F. Retain jurisdiction over this action to assure full compliance with the order of this 

Court and with applicable law; and

G. Grant such additional relief as this Court deems just and proper. 

COUNT IV

Violation Of Illinois General Assembly Public Act 100-1001

165. Plaintiff restates and realleges paragraphs 1-164 as if specifically set forth herein.

166. Under 65 ILCS 5/11-1-12, in pertinent part, a municipality may not require a police 

to issue a specific number of citations within a designated period of time. . . a municipality may 

not, for the purposes of evaluating a police officer’s job performance, compare the number of 

citations issued by the police officer to the number of citations issued by any other police officer 

with similar job duties. 

167. CICERO violated Illinois General Assembly Public Act 100-1001 under 65 ILCS 

5/11-1-12 by utilizing a point system in order to compare the performance of officers whereby 

officers were forced to average a 3.0 point performance on a daily basis and monthly basis which 

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was based on activities of the officers that includes, without limitations, moving violations, parking 

tickets, reports, arrests, gun seizures, and vehicle tows. 

168. CICERO utilized a point system against SINNOTT in order to compare his 

performance to other officers in violation of Illinois General Assembly Public Act 100-1001 under 

65 ILCS 5/11-1-12.

WHEREFORE, Plaintiff respectfully requests that the Court:

A. Find that Defendant discriminated against Plaintiff, in violation of Illinois General 

Assembly Public Act 100-1001 ;

B. Award compensatory and punitive damages to the maximum amount provided by 

statute;

C. Award attorney’s fees, expert witness fees, and costs provided by law;

D. Award forward pay due to the decrease in lower earnings;

E. Retain jurisdiction over this action to assure full compliance with the order of this 

Court and with applicable law; and

F. Grant such additional relief as this Court deems just and proper. 

Respectfully submitted,

/s/ Marc P. Trent___________________________

One of Plaintiff’s Attorneys

Douglas P. Trent (ARDC #2855070)

Marc P. Trent (ARDC #6324928)

TRENT LAW FIRM, P.C.

350 S. Schmale Road, Suite 130

Carol Stream, IL 60188

P: (630) 682-3100

F: (630) 682-3554

attorneys@trentlawfirm.com

Case: 1:20-cv-01917 Document #: 1 Filed: 03/21/20 Page 20 of 20 PageID #:20