A Fourth Amended Sexual Harassment complaint was filed in the United States District Court, Central Division of Illinois, Peoria Division by three former assistant states attorneys against Knox County State's attorney John Pepmeyer. Dean Stone, Michael Kraycinovich and Tracy Jones filed a 15 count complaint, 07-1198, alleging violations relating to sexual harassment, first amendment, 42 U.S.C. Section 1983, wrongful discharge, intentional infliction of emotional distress, libel and slander and State Whistle Blower Protection Statute.
According to the complaint, Illinois attorney Pepmeyer engaged in sexual harassing and discriminating conduct against employees of the Knox County State's Attorney's office including Constance Griffith, Jennifer Brown, Teresa Cummings and Tracy Jones. The three current plaintiff became aware of the sexually harassing conduct and acted in opposition to the conduct which resulted in their termination--which is commonly referred to as retaliation.
All three claim a civil rights violation under 42 U.S.C. Section 1983 which states in part:
"Every person who under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory or the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, Suit in equity, or other proper proceeding for redress, except that in any action brought against a judicial officer for an act or omission taken in such officer's judicial capacity, injunctive relief shall not be granted unless a declaratory decree was violated or declaratory relief was unavailable."