HUD-L-004920-17 12/01/2017 12:11:59 PM Pg 1 of 19 Trans ID: LCV2017564907

LOUIS A. ZAYAS, ESQ.
LAW OFFICES OF LOUIS A. ZAYAS, L.L.C.
8901 Kennedy Boulevard, Suite 5S
North Bergen, NJ 07047
(201) 977-2900

JUAN LUIS RAMOS
Plaintiff,
vs.

CITY OF JERSEY CITY
Defendant.

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) SUPERIOR COURT OF NEW JERSEY
) LAW DIVISION: HUDSON COUNTY
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) Docket No.: HUD-L)
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CIVIL ACTION
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COMPLAINT
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Plaintiff, JUAN LUIS RAMOS, by and through his attorney, LOUIS A. ZAYAS of LAW
OFFICES OF LOUIS A. ZAYAS, L.L.C, alleges the following based on information and belief:
INTRODUCTION
1. The Plaintiff Juan Luis Ramos (“Officer Ramos”) brings these civil rights violations
under the New Jersey Civil Rights Act (“NJCRA”), and the New Jersey Law Against
Discrimination (“NJLAD”) against the City of Jersey City.
2.

The Officer Ramos alleges that he was subjected a hostile work environment since 2007

until his termination in August 2016 because he was perceived by his superior officers and
fellow police officers as untrustworthy or “rat” because he would not adhere to the blue wall of
silence that shielded police officers from accountability for their misconduct.
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3. As a result of this perception, the Defendants harassed, intimidated and retaliated against
Officer Ramos which continued even after he was terminated when the Defendants falsely
represented the circumstances behind his termination in order to deny him much ended
unemployment benefits.
4. Based on their perception that Officer Ramos was engaged in protected activities in
reporting police misconduct, the Defendants retaliated by engaging in a pattern of harassment
and retaliation that included the following adverse employment actions, unfavorable job
assignments, unfounded and retaliatory motivated disciplinary charges, ridiculing his physical
appearance and disability, disparaging him by accusing him of being psychologically “unfit for
duty” based on his postings on Facebook and social media.
5. Defendants terminated Officer Ramos’ employment based on their perception that he was
“unfit for duty” based on a disability that did not prevent him from performing his duties as a
police officer and, in the alternative, the Defendants failed to reasonably accommodate his socalled disability through treatment, counseling or other reasonable measures.
PARTIES
6. Plaintiff Officer Juan Ramos is a citizen of the State of New Jersey and resides in
Hudson County. He was formerly employed as a Police Officer in the Jersey City Police
Department and held this position at all times relevant to this litigation.
7. Defendant City of Jersey City is a municipality organized by virtue of New Jersey law
and pursuant to that law. Defendant City of Jersey City is sued to affect the full declaratory,
injunctive and compensatory damages demanded by the Plaintiff.

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CONDITION PRECEDENT

8. On May 5, 2017, Plaintiff filed a complaint with the Equal Employment
Opportunity Commission alleging violations under the American Disability Act.
9. On August 14, 2017, the EEOC filed a right to sue letter to bring an ADA claim
against the Defendant.
FACTS
10. The Jersey City Police Department has an unwritten and unconstitutional culture that
fosters police misconduct by discouraging police officers from reporting such police misconduct
to appropriate law enforcement authorities. This culture is commonly referred to the “blue wall
of silence”. Under “code of silence, police officers who violate it are retaliated by their fellow
officers through various means, including ostracism, adverse assignments, ridicule, and other
adverse employment actions.
11. On January 7, 2005, Jersey City hired Officer Ramos as a police officer. As a condition
of his employment, Ramos took and successfully passed civil service and Jersey City standard
police examination, which included a background investigation and psychological testing
conducted by Institute for Forensic Psychology (“IFP”).
12. Ramos passed the police examination. As for his psychological examination,
Ramos was examined by IFP and found him fit for duty.
13. On or about the Summer of 2007, contrary to the widely known culture of silence
among police officers, Officer Ramos complained to his supervisor, Lieutenant Peter Sinacore
concerning the legality of a police detail at a construction site.
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In response to Officer Ramos’

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concerns, Lieutenant Sinacore reprimanded Officer Ramos and ignored his complaint. During
that discussion, Lieutenant Sinacore accused Officer Ramos of recording their conversation to
provide to an outside law enforcement agency.
14. Since that encounter with Lieutenant Sinacore were he accused Officer Ramos of
tape recording him, Officer Ramos was perceived as someone who could not be trusted.
Because Officer Ramos was accused of being a rat, every supervisor retaliated against him and
his fellow police officers distrusted him.
15. Because of the perception that Officer Ramos was not to be trusted, police officers began
to harass and retaliate against him.
16. As a result, police officers routinely harassed and retaliated against Officer Ramos,
including humiliating him on the grounds of his weight.

At the time, Officer Ramos was

extremely obese, a disability under the New Jersey Law Against Discrimination.
17. Officer Ramos’ disability subjected to hostile work environment.
18. The harassment was so oppressive that Officer Ramos underwent surgery to remedy his
disability. As a result of the surgery, Officer Ramos’s lost substantial weight.
19. Officer Ramos continued to be harassed and retaliated because of his perceived
whistleblower activities and disability.
20. On or about May 2, 2014, Internal Affairs targeted Officer Ramos because he perceived
by his fellow police officers of recording them involved in official misconduct and corruption.
The Internal Affairs investigation specially questioned Officer Ramos whether he was recording
other police officers with the intent to discourage him from reporting other police officers in
wrongdoing.

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21. The above Internal Affairs investigation took place when federal law enforcement were
investigating numerous Jersey City police department in a corrupt scheme to defraud Jersey City.
The Internal Affairs investigation was designed, in part, to obtain any damaging evidence against
other police officers in order to protect them from criminal liability.
22. Indeed, the United States Attorneys Office for the District of New Jersey indicted
numerous police officers for fraud in off-duty assignments. Defendant has also suspended
numerous police officers based on the same sort of allegations.
23. The Internal Affairs investigation was designed to intimidate and threaten Officer Ramos
from reporting police officers engaged in criminal activities or other wrongdoing.
24. Notably, Internal Affairs failed to conduct an investigation even though they are
responsible for investigating such complaints.
25. Rather than stopping the harassment, Captain Edgar Martinez confirmed to Officer
Ramos that Officer Ramos was the subject of ridicule in the police department in that he “kept
getting unflattering pictures of Officer Ramos on his phone.” Several supervisors told Officer
Ramos in substance: “We think this shit is funny..and told him to let it die out, to ignore it, and
told him that he “needed to have thick skin.”
26. In 2014, Officer Ramos observed a picture of a sumo wrestler marked with Officer
Ramos’ name on Captain Kist’s locker in plain view for other police officers to see and mock.
27. Even after Officer Ramos lost weight after undergoing weight loss surgery, he was
subject to harassment by police officers calling him a “f----ing cheater, you didn’t do it the hard
way.”

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28. Ramos complained to the police department concerning the hostile work environment
based on his disability and harassment. Despite such complaining, Jersey City failed to take any
remedial action to stop it.
29. As a result, Officer Ramos continued to receive harassing comments from other officers
relating to his condition on social media.
30. In March 2015, Officer Ramos posted inspirational pictures of himself onto his social
media in his capacity as a private citizen. Despite their protected activity in expressing himself,
the Defendants launched a retaliatory Internal Affairs investigation to remove him as a police
officer.
31. In or about April 2015, Internal Affairs summoned Officer Ramos and accused him of
violating the police departments’ social media policy. At that time, Internal Affairs Lieutenant
Mark Miller ordered Officer Ramos to go for a fitness for duty examination and removed his
firearm. The Defendants either perceived Officer Ramos as suffering from a disability which
incorrectly prevented him from performing his duties or fabricated a disability to use as a pretext
to fire him.
32. In furtherance of Defendants’ scheme to fabricate a pretext to fire Officer Ramos,
Lieutenant Miller ordered that Officer Ramos obtain a fitness for duty evaluation at the Institute
for Forensic Psychology (“IFP”). The IFP is widely known in the police department that police
officers who are referred to IFP are expected to be diagnosed as “unfit for duty”.
33. Upon information and belief, IFP has a business relationship with Jersey City and other
municipalities to provide fitness for duty reports favorable to the municipality. The IFP is an
independent medical provider since it has a financial self-interest in continuing to receive
business from municipalities. The IFP knows how to render a favorable report based on the

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information it receives from the municipality and ex-parte communications with the referring
agency, i.e. Internal Affairs.
34. Officer Ramos was evaluated by Dr. Schlosser who, as expected, found that Officer
Ramos suffered from “Histrionic Personality Disorder with Narcissistic personality features.” Dr.
Schlosser claims that Officer Ramos was not fit for duty.
35. Dr. Schlosser conspired with Jersey City to fabricate a medical report that he knew was
medically unfounded.
36. In response to Dr. Schlosser’s report, Officer Ramos obtained a psychological report by
Dr. Paul Hriso. According to Dr. Hriso, Officer Ramos was found to be fit for duty.
37. In November 2015, Jersey City again ordered Officer Ramos to appear for a second
evaluation at IFP. The second evaluation was conducted by Dr. Matthew Guller, who is

a

colleague of Dr. Schlosser and also conspired with Jersey City to fabricate the report to falsely
opine that Officer Ramos was not fit for duty.
38. As a result of the unfavorable fitness for duty reports, Lieutenant Miller informed
Officer Ramos Public Safety Director James Shea suspended him without pay indefinitely, and
took Officer Ramos’ badge, police ID, and radio.
39. Officer Ramos complained that such a decision was unlawful, and requested that he be
allowed to be evaluated by New Pathway Counseling Services, an alternative provider for fitness
for duty evaluations for Jersey City employees.

It is widely known that New Pathway

Counseling Services , unlike IFP, routinely approves employees as “ fit for duty.” Upon
information and belief, police officers Anthony and Maria Ruocco, who were similarly accused
of violating the police department’s social media policy, were evaluated by New Pathway
Counseling Services. They were both found to be fit for duty.

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40. When Officer Ramos requested that he also be allowed to be evaluated by New Pathway,
Lieutenant Miller objected and told Officer Ramos that he had little chance of recovery.
Lieutenant Miller, however, told Officer Ramos that if wanted to pay out of his own pocket then
he was free to do so.
41. On March 15, 2016, Officer Ramos was evaluated by Anthony Jenkins from New
Pathway Counseling Service who immediately found Officer Ramos fit for duty. During his
evaluation, Jenkins admitted to Officer Ramos that Jersey City routinely relies on Dr. Guller to
fail police officers and stated “I don’t know how he still has a license to practice.”
42. After obtaining a favorable fitness for duty report from Jenkins, Mr. Jenkins also called
Officer Ramos and demanded that he return the fitness for duty evaluation report because
Pathway was a vendor for Jersey City. Mr. Jenkins told him that the favorable evaluation report
contradicted Jersey City’s position.
43. After Officer Ramos advised Jersey City of the fitness for duty report given by its own
provider, Jersey City initially agreed to have Officer Ramos evaluated by a mutually agreed
independent doctor.
44. Despite the parties agreement to have a neutral medical examiner, Jersey City breached
their agreement and ordered Officer Ramos to be evaluated by its own doctor, Dr. Betty
McLendon at Comprehensive Psychological Services.
45. Not surprisingly, on May 24, 2016, Dr. Betty McLendon submitted a false and unfounded
report that Officer Ramos was unfit for duty.
46. As with the other fabricated evaluations, Officer Ramos presented Jersey City with a
rebuttal examination by Dr. Kristen Szczech and Dr. Paul Hriso, both of who found that Officer
Ramos was not only fit for duty but Dr. McLendon’s report was flawed and unsubstantiated.

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47. Officer Ramos requested a reasonable accommodation based on the faulty conclusions
that he suffered from a disability, including to be placed on modified duty. Jersey City refused to
engage in the interactive process and denied Officer Ramos’ request.
48. On July 25, 2016, Officer Ramos was terminated from his employment.
49. Jersey City continued to retaliate against Officer Ramos even after his termination. In
August 2016, Jersey City falsely claimed in response to Officer Ramos’ application for
unemployment benefits that he was terminated for misconduct.
50. In October 2016, the Department of Labor denied his request for unemployment based
on the misrepresentations from Jersey City, which was a form of retaliation for engaging the
above referenced protected activities.
51. Officer Ramos successfully prevail in his appeal to obtain unemployment benefits.

COUNT I.
NEW JERSEY CIVIL RIGHTS ACT
N.J.S.A. § 10:6-2
47. Plaintiff repeats and realleges the allegations set forth above as if fully set forth herein.

48. Defendants retaliated against Plaintiff based on their perception that he was actually
engaged in reporting police misconduct and corruption to law enforcement, a protected activity
under the statute.
49. The actions of the Defendant were undertaken pursuant to policy, custom and practice.
Jersey City’s blue wall of silence is so pervasive that they carry the force of law.
50. Specifically, Jersey City has a de facto policy, practice or custom of discouraging,
threatening and retaliating against police officers who report police misconduct and corruption,
commonly referred to a “code of silence.” This unconstitutional culture or “code of silence” is
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an understanding between and among police officers resulting in refusal or failure to report
instances of police misconduct by other police officers, including corruption.
51. The “code of silence” is enforced through threats, intimidation, retaliation and other
adverse employment actions. This de facto policy encourages police misconduct since police
officers are subject to disciplinary action and other forms of retaliation if they fail to adhere to it.
The code of silence helps shield police officers from criminal and civil liability.
52. Pursuant to the above de facto policy, practice and custom, Defendants retaliated against
the Plaintiff after he was perceived to be a potential whistleblower and report allegations of
police misconduct.
53. Based on the perception that Officer Ramos was engaged in the above-mentioned
protected activity, Defendant conspired to retaliate against through threats, intimidation, baseless
disciplinary charges, ridicule based on his physical appearance, creating a hostile work
environment, unfavorable work assignments, defamatory assertions that is unfit for duty,
termination and post-termination retaliation.
54. Defendants conduct has directly and proximately caused Plaintiff to suffer economic,
emotional and psychological damages in an amount to be determined by a jury.
WHEREFORE, Plaintiff demands judgment against the Defendants, jointly and severally,
for the following relief:
a. Compensatory Damages;
b. Reinstatement;
b. Punitive Damages;
c. Attorney’s fees and costs of suit;
d. Such other and further relief as the Court deems equitable and just.

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COUNT II
N.J. LAW AGAINST DISCRIMINATION
10:5-12, et seq.
Discrimination Perceived Disability
55. Plaintiff repeats and realleges the allegations set forth as if fully set forth herein.
56. Plaintiff was wrongfully terminated on the basis of his perceived disability despite that
he was performing his duties in a satisfactory manner.
57. Plaintiff was also perceived as suffering from psychological issues including Histrionic
Personality Disorder with Narcissistic personality features.
58. At all times, Plaintiff was fit for duty as a Police Officer, and performed his duties in a
satisfactory manner. Defendant’s perception of his disability was not reasonably related to the
performance of his job duties.
59. As a direct and proximate result of Defendant’s actions, Plaintiff has suffered economic,
emotional, and physiological damages in an amount to be determined by a jury
WHEREFORE, Plaintiff demands judgment against the Defendants, jointly and severally,
for the following relief:
a. Compensatory Damages;
b. Reinstatement;
b. Punitive Damages;
c. Attorney’s fees and costs of suit;
d. Such other and further relief as the Court deems equitable and just.

COUNT II

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LAW AGAINST DISCRIMINATION
10:5-12, et seq.
DISABILITY DISCRIMINATION
Failure to Accommodate/ Interactive Process

60. Plaintiff repeats and realleges the allegations set forth as if fully set forth herein.
61. Plaintiff was also perceived as suffering from psychological issues including Histrionic
Personality Disorder with Narcissistic personality features. This so-called disability, even if a
legitimate psychological condition, did not interfere with Plaintiff’s duties and responsibilities.
62. In addition, the Defendant failed to participate in the interactive process to find a
reasonable accommodation for Plaintiff’s so-called disability, such as counseling or assigning
him to an administrative position.
63. Defendant’s failure to engage in the interactive process or reasonable accommodate
Plaintiff’s perceived disability violated the NJLAD.
64. Plaintiff was not in fact disabled but even if he was disabled, he could have received a
reasonable accommodation such as counselling and treatment, none of which was offered to the
Plaintiff, much less given.
65. As a direct and proximate result of Defendant’s actions, Plaintiff has suffered economic,
emotional, and physiological damages in an amount to be determined by a jury
WHEREFORE, Plaintiff demands judgment against the Defendants, jointly and severally,
for the following relief:
a. Compensatory Damages;
b. Reinstatement;
b. Punitive Damages;
c. Attorney’s fees and costs of suit;

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d. Such other and further relief as the Court deems equitable and just.

COUNT III.
LAW AGAINST DISCRIMINATION
10:5-12, et seq.
RACE DISCRIMINATION
66. Plaintiff repeats and realleges the allegations set forth as if fully set forth herein.
67. Plaintiff is a member of a protected class, namely Hispanic.
68. Plaintiff was unlawfully terminated, in part, on the basis of his race.
69. Plaintiff was performing his duties in a satisfactory manner.
70. Plaintiff was treated disparately from other similarly situated employees with the Jersey
City Police Department, when he was subjected to disparate treatment from similarly situated
white officers, and selective enforcement of rules and regulations, and discipline including
suspension, and termination, due to his race.
71. For example, Defendant’s social media policy is not enforced in a similar matter with
regards to other similarly situated white police officers, who routinely post pictures of
themselves in uniform.
72. Furthermore, the Defendant has not disciplined or treated other similarly situated white
police officers for violating its social media policy.
73. As a direct and proximate result of Defendant’s actions, including terminating him,
Plaintiff has suffered economic, emotional, and physiological damages in an amount to be
determined by a jury.
WHEREFORE, Plaintiff demands judgment against the Defendants, jointly and severally,
for the following relief:

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a. Compensatory Damages;
b. Reinstatement;
b. Punitive Damages;
c. Attorney’s fees and costs of suit;
d. Such other and further relief as the Court deems equitable and just.
COUNT IV.
NEW JERSEY CIVIL RIGHTS ACT
N.J.S.A. § 10:6-2
FREE SPEECH/EXPRESSION
(Social Media)
74. Plaintiff repeats and realleges the allegations set forth above as if fully set forth herein.
75. Defendants retaliated against Plaintiff when, acting under the color of law, and pursuant
to official policy, they subjected Plaintiff to deprivations of his civil rights protected under the
Article 1, Section 18 of the New Jersey Constitution.
76. By posting personal pictures without any relation to the Jersey City Police Department on
his private social media accounts, Plaintiff exercised his right to free speech and expression in a
manner that did not affect the operation of the Police Department.
77. The Jersey City Police Department consequently unlawfully retaliated against Plaintiff
for engaging in protected activity under the New Jersey Constitution, and by creating a content
based restriction that was directly related to Plaintiff’s engaging in speech.
78. Additionally, Defendants retaliated against the Plaintiff after he was perceived to be a
potential whistleblower due to the perception of being an officer who would tape record
incidents of misconduct by fellow officers, and potentially report incidents of police misconduct
by Defendants.

The Jersey City Police Department maintains a “blue wall of silence” which

promotes a culture in which police officers do not report on misconduct regarding other officers
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in the Police Department. Those who break this code and report misconduct, or are perceived of
breaking this code, are retaliated against and ostracized by their fellow officers.
79. Based on the perception that Officer Ramos was engaged in protected activity, or would
potentially engage in protected activity, Defendants attempted to intimidate Plaintiff and engaged
in a continuous pattern of retaliation which culminated in the filing of disciplinary charges and a
subsequent termination of employment.
80. Defendants conduct has directly and proximately caused Plaintiff to suffer economic,
emotional and psychological damages in an amount to be determined by a jury.
WHEREFORE, Plaintiff demands judgment against the Defendants, jointly and severally,
for the following relief:
a. Compensatory Damages;
b. Reinstatement;
b. Punitive Damages;
c. Attorney’s fees and costs of suit;
d. Such other and further relief as the Court deems equitable and just.

COUNT V
AMERICAN WITH DISABILITY ACT
Perception Disability Discrimination

81. Plaintiff repeats and realleges the above allegations herein.
82. Jersey City, in violation of the Americans with Disability Act (“ADA”), 42
U.S.C. §12112(d)(4)(A), had no reasonable basis to believe, based on objective evidence, that
my medical condition would impair my ability to perform the essential job functions of my job
or that Plaintiff would pose a direct threat to myself or others due to a medical condition.
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83. At the time Ramos was sent for a psychological examination, Jersey City sent to IFP a
list of purported disciplinary charges which, after investigation, had not been sustained, except
for minor infraction.
84. Jersey City did not have any reasonable basis to refer Plaintiff for a psychological
examination.
85. As a result of the referral to IFP, which routinely fails employees at the direction of its
municipal clients, Officer Ramos was deemed unfit and terminated.
86. As a direct and proximate result of Defendant’s actions, Plaintiff has suffered economic,
emotional and physiological damages in an amount to be determined by a jury.
WHEREFORE, Plaintiff demands judgment against the Defendants, jointly and severally,
for the following relief:
a. Compensatory Damages;
b. Reinstatement;
b. Punitive Damages;
c. Attorney’s fees and costs of suit;
d. Such other and further relief as the Court deems equitable and just.

COUNT VI
LAW AGAINST DISCRIMINATION
10:5-12, et seq.
Retailation
87. Plaintiff repeats and realleges the allegations set forth as if fully set forth herein.
88. Plaintiff complained to the Defendants that he was not disabled and that the Defendants’
fitness for duty and suspension based on the Defendant’s own biased doctors was unlawful.
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89. In response to Plaintiff’s protected activity, the Defendants unlawfully retaliated against
him by subjecting him to the following adverse employment actions: (1) failure to participate in
the interactive process/ failure to accommodate his perceived disability; (2) subjecting him to
retaliatory disciplinary actions and punishment; (3) terminating his employment, and (4) filing
false and misleading information to the Unemployment Board to delay his unemployment
benefits.
90. As a direct and proximate result of Defendant’s actions, Plaintiff has suffered economic,
emotional, and physiological damages in an amount to be determined by a jury
WHEREFORE, Plaintiff demands judgment against the Defendants, jointly and severally,
for the following relief:
c. Compensatory Damages;
d. Reinstatement;
b. Punitive Damages;
c. Attorney’s fees and costs of suit;
d. Such other and further relief as the Court deems equitable and just.

PRAYER FOR RELIEF
WHEREFORE, Plaintiff demands judgment against the Defendants, jointly and severally,
for the following relief:
a. Compensatory Damages;
b. Punitive Damages;
c. Attorney’s fees and costs of suit;
d. Such other and further relief as the Court deems equitable and just.

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DEMAND FOR JURY TRIAL
Plaintiff hereby demands a jury trial as to all issues so triable.
Dated: December 1, 2017

/s/LOUIS A. ZAYAS
______________________
LOUIS A. ZAYAS, ESQ.

DESIGNATION OF TRIAL COUNSEL
LOUIS A. ZAYAS, ESQ., is designated as trial counsel in this matter.
Dated: December 1, 2017

/s/LOUIS A. ZAYAS
______________________
LOUIS A. ZAYAS, ESQ.

DEMAND FOR PRODUCTION OF INSURANCE AGREEMENTS
Pursuant to R. 4:10-2(b), demand is hereby made that you disclose to the undersigned
whether there are any insurance agreements or policies under which any person or firm carrying
on an insurance business may be liable to satisfy all or part of a judgment which may be entered
in the action or to indemnify or reimburse for payment made to satisfy the judgment. If so, please

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attach a copy of each, or alternative state, under oath and certification: (a) policy number; (b)
name and address of insurer; (c) inception and expiration date; (d) names and addresses of all
persons insured thereunder; (e) personal injury limits; (f) property damages limits; and (g)
medical payment limits.
Dated: December 1, 2017

/s/LOUIS A. ZAYAS
______________________
LOUIS A. ZAYAS, ESQ.

CERTIFICATION PURSUANT TO R. 4:5-1
I certify that the matters in controversy in this action are not subject of any other action
pending in any other court or of a pending arbitration proceeding, and that no other action or
arbitration proceeding is contemplated.
Dated: December 1, 2017

/s/LOUIS A. ZAYAS
______________________
LOUIS A. ZAYAS, ESQ.

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