Former Enid Public Schools campus police chief Mike Dods listens to a question during a special meeting of the Enid Public Schools school board Tuesday, Dec. 10, 2019. 

ENID, Okla. — Former Enid Public Schools Police Chief Michael Dods filed a lawsuit Friday in Garfield County District Court against EPS, Superintendent Darrell Floyd and Assistant Superintendent Randall Rader.

The suit, filed by Oklahoma Education Association attorney Heath Merchen, alleges:retaliation for reporting threatening and/or violent student conduct to law enforcement in violation of state statute; breach of contract; violation of statutory due process; and violations of procedural and substantive due processes.

The suit does not seek a specific monetary amount and instead asks for an amount "to be determined at trial but that is in excess of the amount" required by statute for the filing, which is in excess of $10,000.

The suit also seeks the costs of the lawsuit, attorneys fees, back pay and benefits, future pay and benefits, reinstatement to his position, compensation for emotional harm, compensation for harm to his reputation and other damages the court "deems just and equitable" from the district, Floyd and Rader.

The suit cites the EPS support negotiated contract which states, "An employee shall upon request, have the right to be accompanied by a member of the Association at a conference scheduled by an administrator and/or the Board for the purpose of formal disciplining of the employee by write-up, suspension suspension, demotion or termination."

The suit also cites Oklahoma statute: "After any suspension or prior to any demotion, termination or non-employment, a support employee shall receive notice of the right to a hearing. The hearing shall be conducted by the local board of education. All notices shall be by certified mail, with the postmark used to determine the timeliness of the notice. Failure of the employee to request a hearing within ten (10) working days of such notice shall be considered a waiver of the employee's right to a hearing."

"An officer or employee of a school district or member of a board of education shall notify law enforcement of any verbal threat or act of threatening behavior which reasonably may have the potential to endanger students, school personnel, or school property," according to statute. "Officers or employees of a school district or members of a board of education shall be immune from employment discipline and any civil liability for communication information ... in good faith if they reasonably believe a person is making verbal threats or is exhibiting threatening behavior."

During the 2018-19 school year, Dods investigated allegations a male student assaulted and sexually harassed "multiple" female victims in the school district, according to the suit. The victims reported to Dods that administrators ignored their concerns.

Dods filed a report with Garfield County District Attorney's Office and charges were brought against the student, and a no-contact order was issued for the student and his victims, according to the suit. Dods met with Enid High School Principal Dudley Darrow prior to the beginning of the next school year to confirm the student would not be allowed back on campus due to the court order. Darrow told Dods the student would be back. Dods told the principal he would arrest the student for violating the order if he made contact with the victims. Darrow directed Dods not to arrest the student.

The suit alleges Dods met with Floyd and was told to ask administrators, "What would you like to do?" with respect to charges being filed. Prior to this meeting Dods had not received any form of written discipline for any issue.

On Oct. 2, 2019, Dods went to the Garfield County District Attorney's Office and spoke with an assistant district attorney about a student who repeatedly wielded scissors in the classroom, threatening staff and students, according to the suit. The student, referred to as "student X," is the child of an EPS administrator.

Dods said he wasn't sure how to proceed, especially after being reprimanded about the no-contact order, according to the suit. Dods believed the student presented an ongoing threat and the assistant district attorney told Dods he should file the report.

After he filed the report, Dods received a text message from Rader, stating, "Don't file on XXXX's kid. And if you have, you need to do something to get it stopped." Rader then called Dods and directed him to withdraw the charges, according to the suit. Rader then told Dods to come to his office. Dods said he would like to have his representative present pursuant to the support employees negotiated agreement.

Following the phone call with Rader, Floyd called Dods and "demanded he meet with him immediately," according to the suit. Dods told Floyd he was making arrangements to have a representative present and Floyd was "personally angry that Chief Dods wanted a representative and demanded that he meet with him immediately."

On Oct. 8, 2019, the parties met and Dods was demoted from chief via memorandum: "As a result of your insubordinate actions and fail to follow administrative directives, effective today (Oct. 8, 2019) you no longer have the title of EPS Chief of Police," according to the suit. Dods was placed on a plan of improvement, the purpose of which was to ensure Dods did not report student criminal behavior without an administrator's permission.

Dods was not provided advance written notice of his demotion and was not provided with notice of his right to a hearing before the school board regarding his demotion, according to the suit. Two weeks after his demotion, Floyd sent Dods a termination notice. A termination hearing was held before the EPS Board of Education, and the board voted to terminate Dods.

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Rains is police and court reporter for the Enid News & Eagle. Follow him on Twitter, @cassrains.
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