4:25-cv-02112-SAL-TER Date Filed 03/19/25 Entry Number 1 Page 1 of 14

UNITED STATES DISTRICT COURT

EMMANUEL WILLIAMS, )
)
Plaintiff, )
) COMPLAINT
vs. )
) JURY TRIAL DEMANDED
CITY OF LAKE CITY and )
WILLIAM HALL, in Individual and )
Official Capacities, )
)
Defendant(s). )
___________________________________ )

1. This action is brought to remedy violations Title VII of the Civil Rights Act of 1964,

as amended, 42 U.S.C. §§2000e et seq. (“Title VII”), discrimination based on race.

This action is also brought to remedy Defamation and Promissory Estoppel/Quantum

Meruit/Unjust Enrichment.

2. Compensatory and punitive damages are both sought pursuant to 42 U.S.C. §

1981a(a)(1). Plaintiff also seeks injunctive and other equitable relief, compensatory

and punitive damages, and attorney’s fees pursuant to 42 U.S.C. §§ 1981a(a)(1),

2000e-5(g)(1), (k).

3. Defendant, through City Administration and Council, offered Plaintiff a job, hired

Plaintiff and rescinded the job appointment all in a manner that cause Plaintiff to be

terminated, discriminated against and damaged professionally and personally.

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4. As a result of Defendant’s conduct, Plaintiff suffered offenses and damages as set

forth herein.

5. Plaintiff, a male former employee of Defendant, is a citizen of the United States and

a resident of Chesterfield, South Carolina. Plaintiff is a dedicated public servant who

has devoted his career to the practice of public safety; and he has faithfully and

successfully served in law enforcement for years.

6. Defendant, City of Lake City, upon information and belief, is a municipality

organized and existing under the laws of the State of South Carolina operating

government offices and duties within Lake City to include city management,

maintenance and supervision of Lake City employees and police officers.

7. On information and belief, at all times relevant to the allegations in this complaint,

Lake City was authorized to and did waive any state-law immunity from civil

liability under state-law causes of action by purchasing liability insurance, either by

contract with an insurance company or by participation in an insurance risk pool that

covers the claims raised in this lawsuit.

8. Defendant William Hall is a citizen and resident of Florence County and is the

former Lake City Administrator terminated January 10, 2025.

9. This Court has jurisdiction of this matter and supplemental jurisdiction of state

claims under 28 U.S.C. § 1331 and 1343(a)(3),(4).

10. Pursuant to 28 U.S.C. §1391, venue is properly laid in this district because

Defendants’ conduct substantial, systematic, and continuous activity in this district

and is subject to personal jurisdiction in this district and because all of the acts

underlying this lawsuit occurred in this district.

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11. At all relevant times, Defendant has continuously been an employer engaged in an

industry affecting commerce under Title VII 42 U.S.C.§ 2000e(b).

12. On January 14, 2025, The US Department of Justice, Civil Rights Division issued

Plaintiff a Notice of Right to Sue regarding EEOC Charge 436202402030, with

respect to Title VII.

13. Plaintiff has complied fully with all prerequisites to jurisdiction in this Court under

Title VII of the Civil Rights Act of 1964 and the South Carolina Human Affairs

Laws.

14. A news article dated Friday February 23, 2024, read “Lake City selects new police

chief: ‘A dream come true’”. The article states Plaintiff was the youngest person to

be hired as the police chief in Lake City. He was to start as chief on Monday March

4 and be sworn into office in early April. Lake City Mayor Yamekia Robinson and

Lake City Administrator William Hall believed Plaintiff would be a great leader.

https://wpde.com/news/local/lake-city-police-chief-emmanuel-williams-selection-sergeant-law-

enforcement-passion-career-military-background-investigatons-special-response-tema-resource-

officer-patrol-supervisor-following-jody-cooper-resignation-south-carol

15. Plaintiff went through an interview process with Lake City officials, provided all

information regarding past employment of nearly a decade in law enforcement and

background checks, and Lake City offered Plaintiff, Emmanuel Williams, at age 30

as the Chief of the Lake City Police Department.

16. Defendant presented Plaintiff with a Personnel Action Form signed by the City

Administrator and Plaintiff dated February 23, 2024, signifying Defendants’ offer

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and Plaintiff’s acceptance and signifying Defendant hired Plaintiff for the position

of Police Chief with a start date of March 4, 2024.

17. Plaintiff was chosen over the candidate Major Patrick Miles, a Caucasian male and

member of the Lake City police department who was placed on unpaid

administrative leave in late December as part of an investigation by the South

Carolina Law Enforcement Division for allegations of official misconduct.

18. SLED’s investigation of Major Miles was ongoing from December to March, during

the Lake City’s hiring process for Police Chief.

19. Major Patrick Miles, allegedly performed his own unauthorized investigation into

Plaintiff and/or shared negative information about Plaintiff, that resulted in

Defendant revoking their selection of Plaintiff as police chief.

20. On February 26, 2024, a news article was released “Newly appointed Lake City

Police Chief Fired from Pee Dee law – enforcement job in 2015 over policy

violation.” The violation did not involve any allegation of misconduct. The reporter

allegedly obtained information from the South Carolina Criminal Justice Academy,

but Plaintiff believes the information came from Lake City employees.

https://www.wbtw.com/news/pee-dee/lake-city/newly-appointed-lake-city-police-chief-fired-from-

pee-dee-law-enforcement-job-in-2019-over-policy-violation/

21. On February 28, 2024, a news article was released with the false allegation “Newly

hired Lake City Police Chief backs out of position before beginning duty”. The

article alleges that Lake City Administrator William Hall stated Plaintiff decided to

decline the offer for the position; and that Plaintiff did not say what led to Plaintiff’s

withdrawal.

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https://wpde.com/news/local/newly-appointed-lake-city-police-chief-withdraws-

from-position-emmanuel-williams-terminated-chesterfield-county-sheriffs-office-

policy-violation-not-misconduct-hit-parked-car-south-carolina-february-28-2024

22. Plaintiff was called by Defendant William Hall and forced to resign from the

position. Specifically Plaintiff was threatened that if he did not go quietly,

information from his past and negative press would be released about Plaintiff and

Defendants would not support Plaintiff when the information was released.

Therefore, Defendant Hall coerced and threatened Plaintiff to submit an email

resigning from the position.

23. On March 27, 2024, an article was released about the news conference Mayor

Yamekia Robinson held announcing the City’s new Police Chief Patrick Miles. The

article also states Miles was under investigation by state police in a matter related to

his wife’s arrest in the City of Florence on drug and weapons charges.

https://wpde.com/news/local/lake-city-new-police-chief-patrick-miles-seasoned-

officer-cleared-under-investigation-by-sled-wifes-arrest-news-conference-south-carolina-

march-27-2024

24. Prior to the March article announcing the hiring Patrick Miles as police chief, SLED

had released a statement in a previous December news article : “SLED was

requested by the Florence Police Department on Tuesday December 26 2023 to

investigate Alisa Miles and Patrick Miles regarding allegations of official

misconduct as well as possible weapons and drugs violations. SLED’s investigation

is active and ongoing. “

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https://wpde.com/news/local/alisa-marie-miles-arrested-drugs-gun-sled-joins-

investigation-florence-police-department-melrose-avenue-cwp-methamphetamine-

official-misconduct

25. Plaintiff had not been accused of any misconduct relating to his termination over 10

years before being selected as Lake City police chief. Defendants chose a police

chief who had been accused in 2023 of trying to intervene and get charges against

his wife dismissed after she was arrested on drug and gun charges in December

2023, according to a Florence police lieutenant as part of a SLED investigative

report.

https://www.wbtw.com/news/pee-dee/lake-city/now-lake-city-police-chief-may-

have-tried-to-get-charges-against-wife-dismissed-sled-report-shows-gun-she-was-found-with-

was-his/

26. Plaintiff was subjected to disparate treatment with respect to selection for

employment, the application of background checks, the revocation of job offer, the

forced resignation and the overall terms and conditions of his employment as the

selected police chief. The Caucasian male selected for police chief was not

disqualified for his background information nor subjected to additional background

assessment by Defendant employees after selection; while Plaintiff the African

American male selected for police chief was disqualified after selection and

subjected to additional background assessment by Defendant employees after

selection.

27. Since his selection as Police Chief was announced in the news article February 2024,

with a start date and swear in date, Plaintiff relied on the representations of

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Defendants and believed he had new employment. Based on that belief in the

representations of Defendants, Plaintiff separated from his employer at the time and

lost his income from his former employer.

28. Plaintiff began doing news interviews stating his plans as police chief and his role

within the community.

29. Defendant indicated in news articles and to the public that Plaintiff had been chosen

as police chief; and Plaintiff reasonably relied on those representations.

30. Defendant announced publicly in a news article on February 23, 2024, that Plaintiff

was selected as police chief.

31. Defendant terminated Plaintiff via a phone call between Defendant William Hall and

Plaintiff. Defendant through its representatives then informed Plaintiff.

32. Defendant announced publicly in a news article on February 28, 2024, that Plaintiff

withdrew from the position before beginning his duty, a false claim as Plaintiff’s

phone conversation with Defendant Hall demonstrates Plaintiff was threatened and

forced to resign.

33. Upon information and belief, Defendants through their representative employees,

engaged in conduct to cause defamation of Plaintiff’s character and revocation of a

job position promised to Plaintiff.

34. Defendant’s conduct toward prospective employees and current employees, has

demonstrated unequal treatment based on race that adversely affected minority

employees like Plaintiff and others. Similarly situated employees outside of

Plaintiff’s protected class did not receive this treatment.

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35. Defendant was on notice, or should have been on notice, of the actions of its

subordinates or employees, especially due to Plaintiff’s grievance requests and

appeals directly to council; and all failed to correct such discriminatory actions of

its employees.

36. Defendant has a exhibited a pattern and practice of discriminatory actions against

other minority employees.

a. Defendant Lake City has been sued by former employees for similar actions.

Jody Cooper, African American, resigned from the position of Lake City

Police Chief and resigned as Deputy Administrator and Police Chief in

October 2023 and filed a lawsuit in September 2024

(Case#2024CP2102288), alleging breach of contract, conspiracy and

constructive termination. Specifically, Cooper alleged Defendants hired

Cooper to satisfy “racial appearances” and then undermined his authority

throughout his time of employment.

b. Lake City council voted to move the Mayor’s position to part time along with

a decrease in pay to $27,500 per year. Mayor Yamekia Robinson was the

first female and first African American female to be elected Mayor of Lake

City.

37. Defendants’ acts of discrimination within Defendant’s employment practices and

work environment were performed with malice and reckless indifference to

Plaintiff’s protected civil rights.

38. Defendants’ facially neutral policies and procedures were applied in a discriminatory

manner and in a manner which had a disparate impact on Plaintiff’s Civil Rights.

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39. Defendants’ conduct of forcing Plaintiff’s removal as police chief, and

misrepresenting the manner of Plaintiff’s separation was performed with malice and

reckless indifference to Plaintiff’s reputation and economic interests.

40. As a result of the above referenced conduct of Defendants, Plaintiff has suffered

economic loss, impaired reputation, financial and emotional distress, as well as

attorney fees and costs of litigation.

COUNT I
(TITLE VII – RACE DISCRIMINATION)

41. Plaintiff repeats and realleges each and every allegation contained in preceding

paragraphs of this Complaint.

42. Plaintiff, an African American male, was chosen by Defendants’ selection process

as the chief of police of Lake City, and therefore was deemed eligible for

employment based on passed background check and was deemed qualified for the

position by Defendant.

43. Defendants selected Plaintiff for the job and then revoked its job offer to Plaintiff

and forced Plaintiff’s constructive discharge by threatening to “expose Plaintiff” to

bad press.

44. Defendants then selected a Caucasian candidate for police chief who had bad press

and was under SLED investigation surrounding allegations of official misconduct.

45. Defendants’ claims of Plaintiff’s job offer being revoked due to a termination over

10 years prior, were pretext as the chosen candidate was accused of official

misconduct and still chosen to replace Plaintiff.

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46. Defendants held Plaintiff to a standard different from other Caucasian police chief

candidates with respect to job selection process, policies and procedures.

47. The foregoing actions of Defendant and its representatives discriminated against

Plaintiff on the basis of race in violation of Title VII of the Civil Rights Act of 1964,

as amended, 42 U.S.C. §2000e-2.

48. Plaintiff has suffered injury, including immediate and irreparable injury to include

economic loss, impaired reputation, financial and emotional distress, as well as

attorney fees and costs of litigation, as a direct and proximate result of the

Defendant’s violation of all said rights as alleged herein.

COUNT II
(DEFAMATION)

49. Plaintiff repeats and realleges each and every allegation contained in preceding

paragraphs of this Complaint.

50. Defendants, through representatives and employees, allowed for the publication and

dissemination of the false allegation that Plaintiff abandoned or “backed out” of his

acceptance of the position of police chief.

51. The Defendants allowed for the publication and dissemination of their false

allegations to the public that Plaintiff abandoned or “backed out” of his acceptance

of the position of police chief and insinuated that Plaintiff had a questionable

background check.

52. Such defamatory remarks were published and republished to the public.

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53. The defamatory actions and words of the individual defendants acting as agents and

servants within the course and scope of their employment with Defendant, as set

forth herein, have directly and indirectly promulgated to the public at large the false

insinuation that Plaintiff is unchaste and unfit in his personal and professional life

and character.

54. Such a portrayal is false, known to be false, made with malicious intent to harm the

Plaintiff and in reckless disregard of the truth; and it amounts to defamation per se.

Further, the above constitutes defamation by actions as well as words and

is actionable under the laws of the State of South Carolina; and such defamatory

actions and words are outside of or exceed the scope of any alleged privilege or

immunity.

55. That as a direct and proximate result of the aforesaid defamation, Plaintiff has

suffered, financial and emotional suffering, embarrassment, humiliation, and the loss

of his employment past and future, as well as incurring attorneys' fees and costs.

56. The Plaintiff is further entitled to an award of punitive damages against these

Defendants for their willful, wanton, and malicious conduct. He also seeks attorneys'

fees and the costs associated with bringing this cause of action.

COUNT III
(PROMISSORY ESTOPPEL)

57. Plaintiff repeats and realleges each and every allegation contained in preceding

paragraphs of this Complaint.

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58. The elements of promissory estoppel are 1) an unambiguous promise, 2) reasonable

reliance on the promise by the party to whom it is made, 3) reliance is expected and

foreseeable by the party who made the promise, and, 4) injury in reliance on the

promise. Powers Const. Co. v. Salem Carpets, Inc., 283 S.C. 302, 322 S.E.2d 30 (Ct.

App. 1984).

59. Defendants, through the hiring committee and William Hall made an unambiguous

promise to employ Plaintiff as Chief of Police and publicly announced Lake City’s

decision to select Plaintiff as police chief beginning March 4, 2024.

60. Plaintiff had a reasonable reliance on this public representation of Lake City’s

selection of him.

61. Plaintiff began granting interviews stating his intentions for Lake City regarding law

enforcement and its relationship with the community. Plaintiff also ended his

employment with his former employer based on Lake City’s selection of Plaintiff,

offer and acceptance of the job, publicized start date and swearing in ceremony.

62. Plaintiff’s reliance on Defendant’s representation of job selection and hire was

expected and foreseeable by Defendants as Defendants confirmed to Plaintiff that he

successfully passed Defendant’s selection process, Defendant extended the offer of

employment and received Plaintiff’s acceptance of the offer, and Defendant publicly

declared their selection of Plaintiff as police chief and established a start date and

swearing in date.

63. Plaintiff was injured by Plaintiff’s reliance on Defendant’s promise as Plaintiff lost

his employment with his former employer and his new employment with Defendant.

Plaintiff’s reputation was impaired based on his public acceptance of the position and

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Defendant’s public revocation of the offer and defamatory misrepresentation that

Plaintiff “backed out” of the position voluntarily without explanation. Plaintiff is

entitled to either detrimental reliance or expectation damages.

WHEREFORE, Plaintiff respectfully prays that this Court enter a judgment:

1. Declaring that the acts and practices complained of are in violation of applicable

state and federal laws;

2. Enjoining and permanently restraining these violations of applicable state and federal

laws;

3. Directing Defendants to take such affirmative action as is necessary to ensure that

the effects of these unlawful employment practices are eliminated and do not

continue to affect Plaintiff’s employment opportunities;

4. Directing Defendants to place Plaintiff in the position he would have occupied but

for Defendant’s discriminatory and defamatory treatment of him, and make him

whole for all earnings he would have received but for Defendant’s discriminatory

and defamatory treatment, including, but not limited to, wages, pension and other

lost benefits;

5. Directing Defendant to pay Plaintiff attorney fees, costs, damages for emotional and

financial distress, mental anguish and humiliation; and other compensatory and

punitive damages allowable under 42 U.S.C. §§ 1981a(a)(1), 2000e-5(g)(1), (k) and

all applicable state and federal laws in the amount to be determined by a jury;

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6. Awarding Plaintiff such other and further relief as this Court deems just and proper.

WUKELA LAW FIRM

By: s/ Pheobe A. Clark

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