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COMPLAINT
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EXTRACTED KEY WORDS
PLAINTIFF TROOPER DEFENDANT MARYLAND STATE POLICE BIRTH ACT UNITED STATES CONSTITUTION PRIMARY CARE KEVIN KNUSSMAN COMPLAINT PURSUANT RIGHTS GENDER STATE LAW IMMEDIATE FMLA AMENDMENT MULLINEAUX PRIMARY CARE PROVIDER MSP PERSONNEL MANAGEMENT DIVISION HOWARD KEVIN KNUSSMAN JURY DEMAND CENTREVILLE EMPLOYMENT UNITED STATES DISTRICT POLICE OFFICER SALISBURY AVIATION |
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND NORTHERN DIVISION HOWARD KEVIN KNUSSMAN Plaintiff, v. STATE OF MARYLAND, et. al., Defendants. Civil Action No. B-95-1255 SUPPLEMENTAL COMPLAINT AND JURY DEMAND Nature of the Case In this action, Howard Kevin Knussman, a 20-year veteran police officer with the Maryland State Police, challenges as unlawful MSP's refusal -- expressly on grounds of Trooper Knussman's male gender -- to permit him family leave from work immediately following his daughter's birth, and the retaliatory actions taken against him due to his exercise of his rights to family leave. Claims are brought under the Fourteenth Amendment to the United States Constitution, the Family and Medical Leave Act of 1993, and 42 U.S.C. §1983. Jurisdiction and Venue Jurisdiction lies in this Court pursuant to 28 U.S.C. §§1331 and 1343. Venue is proper in that defendants and plaintiff are residents of the Northern Division of the District of Maryland, and the plaintiff's causes of action arose herein. Parties Plaintiff Howard Kevin Knussman is a male citizen of the United States currently employed in the rank of Trooper First Class with the Aviation Division of the Maryland State Police. Plaintiff is a person within the meaning of the Constitution of the United States, and at all times pertinent to this action Mr. Knussman has been an employee eligible for parental leave within the meaning of the Family and Medical Leave Act of 1993 (FMLA), 29 U.S.C. §§ 2601 et seq. Mr. Knussman has been injured by defendants' acts and omissions as set forth below. Defendant State of Maryland is a government actor within the meaning of the Constitution of the United States, and an employer within the meaning of the FMLA. For purposes of prospective injunctive relief, the State of Maryland is a person within the meaning of 42 U.S.C. §1983. The State, through its agency, the Maryland State Police, employs plaintiff Kevin Knussman as a police officer, and in its capacity as his employer has injured Mr. Knussman and his family as set forth below. Defendant David B. Mitchell is Superintendent of the Maryland State Police, holding theSNIPPETS: |
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