STATE OF MINNESOTA DISTRICT COURT COUNTY …

STATE OF MINNESOTA COUNTY OF HENNEPIN

Arthur Knight, Plaintiff, vs.

City of Minneapolis,

DISTRICT COURT FOURTH JUDICIAL DISTRICT

Case Type: Employment Court File No.: ___________ Judge: __________________

SUMMONS

Defendant.

THIS SUMMONS IS DIRECTED TO THE CITY OF MINNEAPOLIS, BY AND

THROUGH THE OFFICE OF THE CITY CLERK OF MINNEAPOLIS, LOCATED AT

CITY HALL, 350 FIFTH STREET SOUTH, ROOM 304, MINNEAPOLIS,

MINNESOTA 55415.

1. YOU ARE BEING SUED. The Plaintiff has started a lawsuit against you. The Plaintiff's Complaint against you is attached to this summons. Do not throw these papers away. They are official papers that affect your rights. You must respond to this lawsuit even though it may not yet be filed with the Court and there may be no court file number on this summons.

2. YOU MUST REPLY WITHIN 21 DAYS TO PROTECT YOUR RIGHTS. You must give or mail to the person who signed this summons a written response called an Answer within 21 days of the date on which you received this Summons. You must send a copy of your Answer to the person who signed this summons.

3. YOU MUST RESPOND TO EACH CLAIM. The Answer is your written response to the Plaintiff's Complaint. In your Answer you must state whether you agree or disagree with each paragraph of the Complaint. If you believe the Plaintiff should not be given everything asked for in the Complaint, you must say so in your Answer.

4. YOU WILL LOSE YOUR CASE IF YOU DO NOT SEND A WRITTEN RESPONSE TO THE COMPLAINT TO THE PERSON WHO SIGNED THIS SUMMONS. If you do not Answer within 21 days, you will lose this case. You will not

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get to tell your side of the story, and The Court may decide against you and award the Plaintiff everything asked for in the complaint. If you do not want to contest the claims stated in the complaint, you do not need to respond. A default judgment can then be entered against you for the relief requested in the complaint.

5. LEGAL ASSISTANCE. You may wish to get legal help from a lawyer. If you do not have a lawyer, the Court Administrator may have information about places where you can get legal assistance. Even if you cannot get legal help, you must still provide a written Answer to protect your rights or you may lose the case.

6. ALTERNATIVE DISPUTE RESOLUTION. The parties may agree to or be ordered to participate in an alternative dispute resolution process under Rule 114 of the Minnesota General Rules of Practice. You must still send your written response to the Complaint even if you expect to use alternative means of resolving this dispute.

DATED: May 21, 2021

HALLER KWAN LLP

By: /s/ Benjamin R. Kwan Benjamin Reid Kwan (395481) C. Ted Haller IV (396496)

323 Washington Ave. N. Suite 200, T3 Building Minneapolis, Minnesota 55401 612-206-3761 ben@ ted@

Attorneys for Plaintiff

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STATE OF MINNESOTA COUNTY OF HENNEPIN

Arthur Knight, Plaintiff, vs.

City of Minneapolis, Defendant.

DISTRICT COURT FOURTH JUDICIAL DISTRICT

Case Type: Employment Court File No.: ___________ Judge: __________________

COMPLAINT JURY TRIAL DEMANDED

INTRODUCTION In October of 2020, the City of Minneapolis demoted Plaintiff Arthur Knight from the rank of Deputy Chief after he continued to tell the truth about hiring and recruitment policies that have a disparate impact on minorities who want to become police officers. This civil rights complaint seeks a remedy to that retaliatory action that never would have happened but for the fact that Mr. Knight is Black and that he dared to project his voice beyond the Blue Wall of Silence. For nearly three decades on the inside, Mr. Knight has reported and resisted race-biased actions and policies perpetrated by the likes of leaders and fellow police officers. Some actively fought Mr. Knight; many looked away; others just didn't seem to understand.

Until May 25, 2020, when excuses vanished at the intersection of 38th Street and Chicago Avenue South--and countless other intersections around the world--where voices echoed the words and sentiments of Mr. Knight.

Yet where opportunity for good often presents itself, the status quo rears its head to obstruct. Indeed, some white officers acted to silence Mr. Knight. They lobbied the city's Black Chief of Police to do away with the Black man who wouldn't walk their line; and the Chief complied.

Since then, the City of Minneapolis may have put cracks in the Blue Wall of Silence, like when the Chief of Police testified against Derek Chauvin in the disgraced officer's murder trial. But the City must also confront its own internal wall of resistance.

Leaders say the conviction of Derek Chauvin is a beginning. But, so long as Black voices like Art Knight's remain silenced, the City will not move forward and will remain stuck at 38th and Chicago.

PARTIES, JURISDICTION, AND VENUE 1. Plaintiff Arthur Knight ("Plaintiff" or "Mr. Knight" or "Art Knight") is a 52-year-old Black male who resides in the County of Hennepin, State of Minnesota. Until the demotion that is the subject of this lawsuit on October 18, 2020, Mr. Knight was the Deputy Police Chief and Chief of Staff for the Minneapolis Police Department in the Defendant City of Minneapolis. 2. Defendant City of Minneapolis ("Defendant"), is a municipal corporation organized and existing under the laws of the State of Minnesota. The Minneapolis

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Police Department ("MPD") is the primary law enforcement division of Defendant and

is still Plaintiff's employer.

3. The jurisdiction of this Court is invoked, and venue is proper, because

implicated violations of state law occurred in Hennepin County and involve Minnesota

state law.

FACTUAL ALLEGATIONS

Plaintiff's Retaliatory Demotion from MPD Leadership in October 2020

4. This lawsuit seeks a court-ordered remedy to a demotion carried out on

October 18, 2020, as a result of long-running, race-biased headwinds inside the MPD.

5. On that day, the Minneapolis Star Tribune published a lengthy article

about the trouble police departments statewide are having in the recruitment and

retention of non-white police officers.

6. In his role as Deputy Chief and long before, Mr. Knight worked tirelessly

to promote diversity within MPD. Mr. Knight was quoted in the Star Tribune article

about those attempts:

In Minneapolis, budget cuts terminated the Community

Service Officer program, a two-year curriculum that funnels

diverse applicants onto the Police Department while they

earn

their

law-enforcement

degree.

Top brass hopes to restore the program next year but admit

they will have to take another look at the way the agency

recruits, trains and promotes ethnic minorities and women on

the force. If you keep employing the same tactics, said MPD

chief of staff Art Knight, "you're just going to get the same old

white boys."1

1 Liz Sawyer, Amid racial reckoning, departments struggle to attract and retain officers of color, Star Tribune, Oct. 18, 2020,

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