ELECTRONICALLY FILED
6/8/2018 12:44 PM
01-CV-2018-902316.00
CIRCUIT COURT OF
JEFFERSON COUNTY, ALABAMA
ANNE-MARIE ADAMS, CLERK
COMPLAINT
COME NOW, the Plaintiffs, and respectfully shows unto the Court as follows:
PARTIES
Jefferson County, Alabama. The City has an elected City Council and Mayor and
2. Tammi Taylor (Taylor) is over the age of nineteen (19) and a resident of
Adamsville, Alabama.
3. XYZ are those persons who are responsible or who have participated in
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4. This litigation is brought by the City on its own behalf and on behalf of its
FACTS
1. Taylor has been a frequent critic of Adamsville for some years and as will
be set out herein, her conduct has grown increasingly disruptive, threatening and
harassing.
Adamsville relating to speeding tickets given to her and her son. Specifically,
requesting the Mayor to do away with the tickets. The Mayor, Pam Palmer, refused.
demanding a sign on her street stating “Slow. Children Playing.”; however, since there
are already two (2) signs on her street, this request was refused.
demands a stop sign on her street and one (1) was placed at her request.
5. Once again, Taylor attended another Council meeting and claimed that
there was garbage being thrown all over her yard and displayed on Facebook that the
City’s Public Works employees were ripping open bags and strewing the garbage in her
yard. Unbeknownst to Taylor, there were cameras on the garbage trucks and when
reviewed there was no depiction of any kind on the day Taylor claimed the City
employees threw garbage on her yard of any such thing. As a result, Mayor Palmer
informed her that the allegations were untrue and requested that she not post such
untruth on Facebook.
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6. During the election cycle for 2016, Taylor attempted to fill out the proper
paperwork to run for Mayor; however, as she failed to fill out an Economic Interest
State would not place her name on the ballot. Importantly, Taylor had been provided all
the necessary documents as well as an election handbook which clearly set out all
required filings to be properly placed on a ballot. Taylor, however, despite her failure to
7. In August, 2016, Mayor Palmer ran into Taylor and Taylor told the Mayor
that she was a Christian and that she loved the Mayor. The Mayor responded that, “No,
you don’t, you hate me.”, to which Taylor replied “Yes, I do.” This conversation took
Once outside Dan’s, Taylor reiterated to the Mayor that “I really do hate
you.”, explaining that the first time she met the Mayor at City Hall she asked the Mayor
example from the summer of 2016 is the following post by her on her Facebook page:
posting on the City’s Facebook page due to the inciteful, harassing and belligerent
nature of her posts. As a result, in December, 2016, a day before the annual
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Adamsville Christmas Parade, Taylor either came to or called City Hall, was angry, and
demanded that Pam McPherson, a City employee, place Taylor back on the Facebook
page. The Mayor was at her place of business at the time and Taylor called her there
and demanded that she be allowed access to the City’s Facebook page. At some point,
according to the Mayor, Taylor stated “I ought to blow that bitch off that float”. This was
in reference to the Mayor riding on a float the next day in the parade.
A police report was filed concerning this incident. The threat was taken
seriously by the City to the extent that special needs individuals were not allowed to ride
on a special float and a sniper rode with the Mayor. The concern was also heightened
by Taylor posting on her Facebook page a few days before this incident about her
On or about February 6, 2017, after the Mayor had been out of town for a few days,
there was a package at her home from Walmart containing angel hair pasta.
included that Mayor Palmer is “VILE”, “DISGUSTING” and “UNFIT” and that “The mayor
is off her rocker if she thinks she can run our city as if she is Hitler. #thisisnotnorthkorea
#pamkimjongun”
11. Taylor also posted around this time that Mayor Palmer is a “snake” and a
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me otherwise.”
13. Taylor has included in a post that “This post right here proves how
crooked and untrustworthy Pam Palmer and Janna Gardner is.” Ms. Gardner is the City
Clerk.
14. Throughout this year, Taylor has posted false statements about the landfill
in Adamsville, which is regulated by a duly established and lawful solid waste authority,
to include disseminating false information about funds allegedly received by the City
and blaming the City for activities over which it has no control.
“I believe the main issue is not the volume Big Sky was
bringing in…but how they violated community zoning
laws to bring it in under our nose. It is all underhanded
and wrong. The people were not notified.”
15. On February 16th of this year, in connection with a public record request
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16. On February 17th of this year, Taylor posted that “Dealing with the open
individual.
18. In one post on February 20th of this year, Taylor boasted that “We
19. On March 2nd of this year, Taylor, in a post about an Adamsville Police
20. On March 6th of this year, due to continual phone calling to City Hall by
Taylor, at least ten (10) calls from 10:30 AM to 4:00 PM, a police report was made.
Taylor would call and speak with either Pam McPherson, Amanda Morrow or Jennifer
Jones or Janna Gardner or would leave messages. All calls were harassing and
Taylor’s tone was belligerent and threatening. When Ms. Jones spoke with Taylor she
was so shaken by how aggressive and belligerent Taylor was that it affected her work
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performance for the rest of the day. This constant calling interferes with the City
21. On March 7th of this year, Taylor posted an article entitled “Political
Nepotism is Making Leaps and Bounds”, referring to the Mayor of New York and his
“The Mayor & City Clerk get angry with you (the tax
paying citizen) ask them basic questions to hold and
keep them accountable. That is the true character/result
of a tyrannical government for running amuck.”
23. On March 11th of this year, in response to a post about the human waste
24. On or about March 11th of this year, again discussing the human waste
They just don’t treat people like they way they have
been treating us. Wring [sic], heartless and selfish led
by greed and love of money. PURE SICK!”
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25. On March 13th of this year, Taylor included in a post that the untruth that
John Cameron, the City’s former Public Works Director, was fired from this position and
26. On March 14th of this year, Taylor posted that State Representative Juan
Dalynn Givan laughed “in our face when she was contacted” about the landfill issue and
27. On March 19th of this year, Taylor posted that the Mayor and City Clerk
28. Over the last several months, on numerous occasions, the Mayor has
been followed by a white van. On one occasion the Mayor was able to see the tag and
On one (1) occasion, when the Mayor was followed home, a person in the
vehicle stopped and informed the Mayor that she was going a little fast down the road
and that he was watching her. Behind the white vehicle was a pick-up truck and the
person in that vehicle slowed down and yelled at the Mayor “We have our eyes on you.”
29. On March 26th of this year, Taylor went to City Hall and asked Pam
McPherson if “Darby” was a City employee. Ms. McPherson responded she did not
think so and Taylor then asked Ms. Gardner who responded “No”, although will help out
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the City sometimes if needed. Taylor responded “I have videoed her driving a city car at
7:52 AM”; however, the individual Taylor thought was Darby was someone else who is a
City employee and was driving her own car to work. In addition, Taylor has posted that
she was following Darby while Darby was driving a City car, which is false.
30. After a recent Council Meeting attended by Taylor, she parked her vehicle
next to the Mayor’s and left a bag with feces next to the Mayor’s vehicle.
31. Taylor has followed a City Councilman demanding that he tell her what
32. Due to the constant harassment of the City employees, either through the
telephone or Taylor coming to City Hall, new locks and cameras have been added as
33. Recently, Taylor called City Hall and asked Pam McPherson in an
intimidating manner if she was afraid of her. Ms. McPherson was startled and is afraid.
34. Recently, Taylor is now representing she is acting with the City in
connection with her perceived issues with the landfill when she has no authority or
permission to represent, suggest or imply that she is acting on behalf of the City or its
elected officials.
35. The acts and conduct of Taylor alleged above is pervasive and continuing
in nature.
36. The acts and conduct of Taylor alleged above are intimidating, vengeful,
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the Plaintiffs’ status as public officials in that they are false and are intentionally made
with knowledge of their falsity and lack of truth and with a purposeful disregard of the
same. Moreover, the communications by Taylor are harassing and are made with the
intent to provoke.
38. The City and its employees have no adequate remedy at law due to the
39. There has been and will continue to be irreparable harm to the City, its
elected officials and employees if Taylor is not enjoined from the conduct and
communications set out above. The City does not have an adequate remedy at law as
due to the continuing nature and pattern of Taylor’s conduct and unless enjoined, Taylor
follows:
1. That the Court, after a hearing, enter a Preliminary Injunction enjoining the
c. Being present at City Hall unless with permission from the Mayor or
City Clerk and only with the City first arranging for adequate
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security.
officials or employees.
2. That the Court enter any other further or different relief to which the
/s James S. Ward
JAMES S. WARD
Attorney for Plaintiffs
OF COUNSEL:
WARD & COOPER, LLC
2100 Southbridge Parkway, Suite 580
Birmingham, AL 35209
(205) 871-5404
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