By successfully filing your claim, you have certified that all information provided is true and correct to
the best of your knowledge and belief. You also understand that the willful making of any false
statement of material fact herein may subject you to criminal penalties and civil liabilities.
201800044275
You uploaded:
Claim Form: 1
Supporting Documents:0
5/9/2018 5:41 PM
Claimant Last Name:Terrell
Claimant First Name:David
Office of the New York City Comptroller
1 Centre Street
New York City Comptroller
New York, NY 10007
Scott M. Stringer
Form Version: NYC-COMPT-BLA-PI1-D
*Manner in which
claim arose: Claimant alleges that since his appointment to the Department on July 1, 2002, he has been subjected to the
'random drug testing program.'
Claimant alleges that the Department administers the 'random drug testing program' under the guise of the 'public
safety sensitive position' exception.
Claimant alleges that the Department administers the 'random drug testing program' under threat of suspension
and termination.
Claimant alleges that under Department guidelines, the employee 'must' report and provide a urine and/or hair
sample.
Claimant alleges that under Department guidelines, the employee 'cannot' challenge the 'veracity' of the results to
the detriment of African-Americans and other officers of color.
Claimant alleges that the Department 'claims' the 'random drug testing program' computer algorithm doesn't
include an employees' race or national origin.
Claimant alleges that the Department manages the 'random drug testing program' using a computer algorithm
created and/or maintained by the Medical Division.
Claimant alleges that the Department through the Medical Division 'manipulates' the 'random drug testing
program' using a computer algorithm intentionally testing African-American and other officers of color more often
than similarly situated Caucasian officers.
Claimant alleges that the Department through the Medical Division have tested more African-American and other
officers of color meanwhile, failed to test similarly situated Caucasian officers.
Claimant alleges that the Department through the Medical Division uses the 'random drug testing program' to
intentionally discriminate against African-American and other officers of color in favor of similarly situated
Caucasian officers.
Claimant alleges that the Department through the Medical Division use of the 'random drug testing program' have
a 'disparate impact' upon African-American and other officers of color in favor of similarly situated Caucasian
officers.
Claimant alleges that the Department through the Medical Division use the 'random drug testing program' to
retaliate against African-American and other officers of color whenever they complain about discrimination and
other serious misconduct in the workplace.
Claimant alleges since July 1, 2002, he has been tested numerous times under the 'random drug testing program'
meanwhile other similarly situated Caucasian officers have never been tested.
Claimant alleges that on or about September 23, 2017, March 15, 2018 and April 27, 2018, the Department with
knowledge of the his filing a Notice of Claim, EEOC Charge of Discrimination and federal civil rights lawsuit, under
the guise of the 'random drug testing program' retaliated against him subjecting him to further testing.
The items of $5 Million Dollars (Pain and Suffering, Mental Anguish and Punitive Damages)
damage or injuries
claimed are
(include dollar
amounts):
Office of the New York City Comptroller
1 Centre Street
New York City Comptroller
New York, NY 10007
Scott M. Stringer
The Total Amount Claimed can only be entered once the following
required fields are entered:
I certify that all information contained in this notice is true and correct to the best ofmy knowledge and belief I understand that the willful
making ofany false statement ofmaterial fact herein will subject me to criminalpenalties and civil liabilities.