Lawsuit Filed Against Jamie Devine, Richland One School Board

ELECTRONICALLY FILED - 2024 Aug 19 4:31 PM - RICHLAND - COMMON PLEAS - CASE#2024CP4005067
STATE OF SOUTH CAROLINA IN THE COURT OF COMMON PLEAS
COUNTY OF RICHLAND CASE NO.: 2024-CP-40-
Ali De La Cruz,
Plaintiff, SUMMONS
vs.
Jamie Devine, in his official and individual

capacities, and Richland One Board of School
Commissioners,
Defendants.
A lawsuit has been filed against you. YOU ARE HEREBY SUMMONED and required to
answer the Complaint in this action, of which a copy is hereby served upon you, and to serve a
copy of your answer to the Complaint to said Plaintiff’s attorney the address listed below within
thirty (30) days after such service. If you fail to do so, judgment by default will be rendered against
you for the relief demanded in the Complaint. You also must file your Answer or Motion with the
court.
LAW OFFICE OF TYLER RODY, LLC
S/Tyler Rody
Tyler Rody, Bar No. 104238
661 E. Main St.
Spartanburg, SC 29302
(864) 381-7969
(864) 670-5636 – Fax
[email protected]
Attorney for Plaintiff
Spartanburg, SC
August 19, 2024
STATE OF SOUTH CAROLINA IN THE COURT OF COMMON PLEAS
COUNTY OF RICHLAND CASE NO.: 2024-CP-40-
Ali De La Cruz,
Plaintiff, COMPLAINT
vs. (Jury Trial Requested)
Jamie Devine, in his official and individual

capacities and Richland One Board of School
Commissioners,
Defendants.
Plaintiff, complaining of Defendants would respectfully show unto the Court as follows:
PARTIES
1. Plaintiff Ali De La Cruz, hereinafter referred to as “Plaintiff,” is a resident of Richland
County, South Carolina.
2. Defendant Jamie Devine, (Defendant Devine) is a resident of Richland County, South
Carolina and a citizen of the United States of America. Defendant Devine is a state actor
and a “person” as that term is defined in relation to 42 U.S.C. § 1983. He is sued herein for
his acts individually and in his official capacity as a member of the Richland One Board of
School Commissioners.
3. Richland One Board of School Commissioners, (hereinafter Defendant School Board) is
an authorized political subdivision of the State of South Carolina that is statutorily liable,
both directly and vicariously, for the acts of the individual Defendant and the damages to
Plaintiff under the South Carolina Tort Claims Act, S.C. Code § 15-78-10 et seq., and is
also liable pursuant to 42 U.S.C. § 1981 and 1983 for the damages suffered by Plaintiff due
to its supervisory indifference and/or tacit authorization of the misconduct of its agents as
detailed herein.
JURISDICTION AND VENUE
4. Jurisdiction and venue in this Court are proper under S.C. Code Ann. § 15-78-100(b), as
the acts and/or omissions giving rise to this action were committed, either in whole or in
part, in Richland County, South Carolina.
5. Plaintiff further invokes this Court’s concurrent jurisdiction to hear claims against
Defendant Devine and Defendant School Board arising under the Constitution and federal
statutes, specifically, 42 U.S.C. § 1983, 1988, and the First and Fourteenth Amendments
to the United States Constitution.
FACTUAL BACKGROUND
6. The above allegations are hereby incorporated as if fully stated herein.
7. Plaintiff is an adult education teacher and employed by Richland County School District
One (hereinafter Richland One).
8. Plaintiff regularly attends school board meetings held by Defendant School Board in a
public forum to stay informed and to exercise her right to participate in public discourse.
As such, she regularly speaks at Defendant School Board’s meetings and regularly offers
objective criticism of Defendant School Board’s and Richland One’s actions.
9. Upon information and belief, on or about April 23, 2024, Plaintiff attended a regularly
scheduled public school board meeting held by Defendant School Board.
10. During the April 23, 2024, meeting, Plaintiff made comments as part of the public
participation segment.
11. In that meeting, Plaintiff criticized Richland County School District One for failing to
evaluate her daughter, who has ADHD and attends a school in its district, after Plaintiff
made several requests for her to be tested and evaluated. Plaintiff further criticized
Richland One for changing her daughter’s classes and failing to implement an education
plan for her daughter, and she criticized Defendant School Board for its budgeting and not
being able to hire psychologists who can assist kids with testing for learning disabilities
and/or challenges.
12. At all times relevant herein, Defendant Devine was a board member for Defendant School
Board.
13. Upon information and belief, during the April 23, 2024, school board meeting and after
Plaintiff’s participation in the public segment, Defendant Devine took multiple
inappropriate, “upskirt” photographs of Plaintiff without her knowledge or consent while
she was sitting in the front row of the meeting next to her husband.
14. Upon information and belief, the cell phone used by Defendant Devine to take the
inappropriate photographs was the property of Defendant School Board and/or Richland
County School District 1.
15. Defendant Devine was acting within the scope of his employment and/or official duties
with Defendant School Board when taking and distributing the inappropriate photographs
he took of Plaintiff, as these events took place while he was performing the duties of a
school board member during a school board meeting.
16. Upon information and belief, Defendant Devine distributed the inappropriate photographs
to others via text message, messaging application, and/or email to harass, intimidate, and/or
embarrass Plaintiff.
17. Upon information and belief, Defendant Devine took the photographs for his own sexual
gratification, and/ or for the sexual gratification of the individuals to which he distributed
the photographs.
18. As a result of Defendant Devine’s actions, Plaintiff has experienced emotional distress,
embarrassment, and other damages that will be outlined in this Complaint.
19. Either Defendant School Board is statutorily liable for the actions and omissions of
Defendant Devine brought under the South Carolina Tort Claims Act as an employee/agent
acting in the course and scope of his official duties pursuant to the South Carolina Tort
Claims Act, or Defendant Devine’s conduct outlined above constitutes intent to harm or a
crime of moral turpitude and he is individually liable.
20. Defendant School Board is liable for the constitutional violations of Defendant Devine for
its policies, training, and/or customs that allowed the behavior to take place.
FOR A FIRST CAUSE OF ACTION

42 U.S.C. § 1983 – Retaliation in Violation of the First Amendment
(As to Defendant Jamie Devine)
21. Plaintiff restates and realleges all previous paragraphs as if they are restated herein
verbatim.
22. 42 U.S.C. § 1983 provides that:
Every person, who under color of any statute, ordinance, regulation, custom
or usage of any state or territory or the District of Columbia subjects or
causes to be subjected any citizen of the United States or other person within
the jurisdiction thereof to the deprivation of any rights, privileges or
immunities secured by the constitution and law shall be liable to the party
injured in an action at law, suit in equity, or other appropriate proceeding
for redress. . .
23. Plaintiff in this action is a citizen of the United States and Defendant Devine is a person
for purposes of 42 U.S.C. § 1983.

24. At the time of the complained of event, Plaintiff had the clearly established constitutional
protections to be free from retaliation for the exercise of protected speech.
25. Any reasonable school board member such as Defendant Devine knew or should have
known of this right at the time of the complained of conduct as it was clearly established
at that time.
26. Plaintiff exercised her constitutionally protected right to question the conduct of the
government and/or engaged in protected speech by speaking at Defendant School Board’s
meetings, which were public forums.
27. Because of his dissatisfaction with Plaintiff’s critical comments about Defendant School
Board and Richland One, Defendant Devine retaliated against Plaintiff and attempted to
embarrass and harass her by taking upskirt photographs of her while she was attending the
school board meeting and by distributing those photographs to others.
28. Retaliatory animus for Plaintiff’s exercise of her constitutionally protected right to question
the conduct of the School Board, was a substantially motivating factor in the retaliatory
taking of inappropriate “upskirt” photographs of Plaintiff by Defendant Devine.
29. The actions taken against Plaintiff in retaliation for her protected conduct would deter a
person of ordinary firmness from continuing to engage in the protected conduct of speaking
at future School Board meetings.
30. Defendant Devine took inappropriate photographs of Plaintiff as a means of retaliation for
Plaintiff’s protected speech. He is therefore liable for violating Plaintiff's First Amendment
protections.
31. Defendant Devine is not entitled to qualified immunity for the complained of conduct.
FOR A SECOND CAUSE OF ACTION
42 U.S.C. § 1983 – Deliberately Indifferent Policies, Practices, Customs, Training, and
Supervision in violation of the First Amendment pursuant to Monell v. Dept. of Soc. Servs., 436
U.S. 658 (1979).
(As to All Defendants)
verbatim.
33. At the time of the complained of event, Plaintiff had the clearly established constitutional
protections to be free from retaliation for the exercise of protected speech.
34. Defendant Devine and Defendant School Board knew or should have known of these rights
at the time of the complained of conduct as they were clearly established at that time.
35. Defendants are not entitled to qualified immunity for the complained of conduct.
36. Defendant Devine and Defendant School Board were at all times relevant herein,
policymakers for Defendant School Board and in that capacity established policies
procedures, customs, and/or practices for Defendant School Board. At all times relevant
herein, Defendant Devine was acting under the color of state law in his capacity as board
member of Defendant School Board and his acts or omissions were conducted within the
scope of his official duties or employment.
37. These Defendants developed and maintained policies, procedures, customs, and/or
practices exhibiting deliberate indifference to the constitutional protections of citizens,
which were moving forces behind and proximately caused the violations of the Plaintiff’s
constitutional protections and federal rights as set forth herein and in the other claims,
resulted from a conscious or deliberate choice to follow a course of action from among
various available alternatives.

38. Defendant Devine and Defendant School Board have developed and maintained long-
standing, department-wide customs, policies, procedures, practices, and/or failed to
properly train and/or supervise its employees/ members in a manner amounting to
deliberate indifference to the constitutional protections of Plaintiff and of the public.
39. The deliberately indifferent training and supervision provided by Defendant Devine and
Defendant School Board resulted from a conscious or deliberate choice to follow a course
of action from among various alternatives available to Defendants and were moving forces
in the constitutional and federal violations complained of by Plaintiff.
FOR A THIRD CAUSE OF ACTION

Negligence/Gross Negligence
(As to Defendant Devine)
verbatim.
41. As a public official and board member at a public-school board meeting, Defendant Devine
owed a duty of care to the public in attendance at the meeting and to Plaintiff to act
reasonably and not to cause them unnecessary harm.
42. Defendant Devine breached his duty of care to Plaintiff and was negligent, grossly
negligent, reckless, and/or willful by taking inappropriate upskirt photographs of Plaintiff
and distributing them to others.
43. Upon information and belief, Defendant Devine’s actions were taken with intent to harm
Plaintiff and constitute a crime involving moral turpitude.
44. As a direct and proximate result of the negligent/ and/or reckless, willful, and wanton acts
of Defendant Devine, Plaintiff has been unable to engage in her normal pursuits of
happiness, suffered emotional distress, pain, discomfort, mental anguish, alteration of

lifestyle, loss of enjoyment of life, and other damages that may be later determined and/or
proven.
45. Defendant Devine’s conduct of taking and then distributing the inappropriate photographs
of Plaintiff constituted a crime of moral turpitude and he acted with intent to harm and
embarrass Plaintiff, therefore, he can be individually named and liable for this cause of
action under the South Carolina Tort Claims Act.
FOR A FOURTH CAUSE OF ACTION

Negligence/Gross Negligence
(As to Defendant School Board)
verbatim.
47. Defendant School Board is statutorily liable to Plaintiff for the negligent, grossly negligent,
and/or reckless acts of Defendant Devine as outlined herein to the extent that they were
undertaken within the scope of his employment and/or official duties with Defendant
School Board.
48. Furthermore, Defendant School Board owed a duty to the public in attendance at its school
board meetings and to Plaintiff to act reasonably and not to cause them unnecessary harm.
49. Defendant School Board breached its duty of care to Plaintiff and was negligent, grossly
negligent, reckless, and/or willful in one or more of the following particulars, to wit:
a. Choosing not to adequately train personnel;
b. Choosing not to adequately manage personnel;
c. Choosing not to adequately supervise personnel;
d. Choosing not to enforce its policies and procedures;

e. Choosing to allow a school board member to use school board property for
harassing, intimidating, and/or illegal purposes; and
f. In other such particulars that may be found in discovery and/or trial.
50. As a direct and proximate result of the negligent/ and/or reckless, willful, and wanton acts
of Defendant School Board, Plaintiff has suffered damages as outlined in this Complaint
and incorporated into this cause of action.
FOR A FIFTH CAUSE OF ACTION

Intentional Infliction of Emotional Distress
verbatim.
52. Defendant Devine took upskirt photographs of Plaintiff during a school board meeting and
then distributed the photographs to others in an attempt to harass, humiliate, intimidate,
and belittle her.
53. Defendant Devine intentionally or recklessly inflicted emotional distress on Plaintiff, or he
was certain or substantially certain that such distress would result from its conduct.
54. Defendant’s conduct was so extreme and outrageous as to exceed all possible bounds of
decency and must be regarded as atrocious and utterly intolerable in a civilized community.
55. Defendant caused Plaintiffs’ emotional distress, which was so severe that no reasonable
person could be expected to endure it.
56. Defendant Devine was intentionally trying to harm Plaintiff by taking and then distributing
the inappropriate photographs. Furthermore, Defendant Devine’s conduct of taking and
then distributing the inappropriate photographs of Plaintiff constitutes a crime involving
moral turpitude.
FOR A SIXTH CAUSE OF ACTION
Voyeurism constituting negligence per se
verbatim.
58. Defendant Devine was required to obey the laws of South Carolina.
59. Defendant Devine owed a duty to Plaintiff to follow the rules, laws, and procedures under
South Carolina Law in such a manner to avoid injury to Plaintiff.
60. Defendant Devine failed to obey South Carolina law in violation of S.C. Code Ann. § 16-
17-470(B) which states “A person commits the crime of voyeurism if, for the purpose of
arousing or gratifying sexual desire of any person, he or she knowingly views, photographs,
audio records, video records, produces, or creates a digital electronic file, or films another
person, without that person’s knowledge and consent, while the person is in a place where
he or she would have a reasonable expectation of privacy.”
61. Plaintiff had a reasonable expectation of privacy sitting in the front row of a school board
meeting, and the front row of Defendant School Board’s meetings is a place where one
would reasonably expect to be safe from hostile intrusion or surveillance, especially from
the school board members themselves.
62. As a direct and proximate result of Defendant Devine’s violation of South Carolina’s laws,
including the one identified above, Defendant Devine breached his duty to Plaintiff to
follow the rules, laws, and procedures under South Carolina law.
63. As a result of Defendant Devine’s failure to follow the laws of South Carolina, Plaintiff
suffered damages as outlined in this complaint and incorporated into this cause of action.
64. Defendant Devine’s conduct of taking and then distributing the inappropriate photographs
of Plaintiff constituted a crime of moral turpitude and he acted with intent to harm Plaintiff,
therefore, he can be individually named and liable for this cause of action under the South
Carolina Tort Claims Act.
FOR A SEVENTH CAUSE OF ACTION

Voyeurism constituting negligence per se
verbatim.
School Board.
67. At all times relevant herein, Defendant Devine was acting within the course and scope of
his employment/ official duties with Defendant School Board.
68. Therefore, Defendant School Board is statutorily liable to Plaintiff for the negligent,
grossly negligent, and/or reckless acts of Defendant Devine as outlined herein.
FOR AN EIGHTH CAUSE OF ACTION

Aggravated Voyeurism constituting negligence per se
verbatim.
70. Defendant Devine was required to obey the laws of South Carolina.
71. Defendant Devine owed a duty to Plaintiff to follow the rules, laws, and procedures under
South Carolina Law in such a manner to avoid injury to Plaintiff.

72. Defendant Devine failed to obey South Carolina law in violation of S.C. Code Ann. § 16-
17-470(C) which states “A person commits the crime of aggravated voyeurism if he or she
knowingly sells or distributes any photograph, audio recording, video recording, digital
electronic file or film of another person taken or made in violation of this section.”
73. Upon information and belief, Defendant Devine distributed the inappropriate photographs
that he took of Plaintiff to several individuals via text message, messaging apps, and/or
email.
74. Defendant Devine violated S.C. Code Ann § 16-17-470(B) by taking the aforementioned
photographs and further violated § 16-17-470(C) by distributing the photographs.
75. As a direct and proximate result of Defendant Devine’s violation of South Carolina’s laws,
including the one identified above, Defendant Devine breached his duty to Plaintiff to
follow the rules, laws, and procedures under South Carolina law.
76. As a result of Defendant Devine’s failure to follow the laws of South Carolina, Plaintiff
suffered damages as outlined in this complaint and incorporated into this cause of action.
77. Upon information and belief, Defendant Devine’s conduct of taking and then distributing
the inappropriate photographs of Plaintiff constituted a crime of moral turpitude and he
acted with intent to harm Plaintiff, therefore, he can be individually named and liable for
this cause of action under the South Carolina Tort Claims Act.
FOR A NINTH CAUSE OF ACTION

Aggravated Voyeurism constituting negligence per se
verbatim.
School Board.
80. At all times relevant herein, Defendant Devine was acting within the course and scope of
his employment/ official duties with Defendant School Board.
81. Therefore, Defendant School Board is statutorily liable to Plaintiff for the negligent,
grossly negligent, and/or reckless acts of Defendant Devine as outlined herein.
FOR A TENTH CAUSE OF ACTION

42 U.S.C. § 1983 – Violation of the Equal Protection Clause of the Fourteenth
Amendment
verbatim.
83. Defendant Devine was a state actor at all times relevant herein.
84. Defendant Devine harassed Plaintiff because of her sex as a female, and he would not have
taken the same or similar photographs had Plaintiff been a male.
85. Furthermore, Defendant Devine has not harassed males that have spoken at school board
meetings and engaged in criticism of Richland One and Defendant School Board at those
meetings. Scott Barber, who is a male, has regularly spoken at the meetings and criticized
Richland One and Defendant School Board but has not been subjected to harassment by
Defendant Devine or Defendant School Board.
86. Defendant Devine’s harassment of Plaintiff was severe and pervasive in the following
particulars, to wit:
a. In taking upskirt photographs of Plaintiff without her knowledge or consent during
a school board meeting;
b. In distributing the photographs to others in an attempt to belittle, humiliate and
embarrass Plaintiff on the basis of her sex and tarnish her reputation, which resulted
in a countless number of people eventually seeing the photographs.
87. As a direct and proximate result of the constitutional violations committed by Defendant
Devine, Plaintiff suffered embarrassment, humiliation, and other damages as outlined
herein and incorporated into this cause of action.
88. Defendant Devine is not entitled to qualified immunity, as Plaintiff’s right to be free from
sexual harassment from state actors was clearly established at the time.
FOR AN ELEVENTH CAUSE OF ACTION

42 U.S.C. § 1983 – Deliberately Indifferent Policies, Practices, Customs, Training, and
Supervision in violation of the Equal Protection Clause of the Fourteenth Amendment
pursuant to Monell v. Dept. of Soc. Servs., 436 U.S. 658 (1979).
(As to All Defendants)
verbatim.
90. Plaintiff was subjected to discriminatory sexual harassment in the form of inappropriate
photographs being taken of her and sent to others. The harassment occurred because of and
on the basis of Plaintiff’s sex, and the sexual harassment would not have occurred had
Plaintiff been a male.
91. At the time of the complained of event, Plaintiff had the clearly established protections to
be free from sexual harassment by Defendant Devine.
92. Defendants knew or should have known of these rights at the time of the complained of
conduct, as they were clearly established at that time.
93. Defendants are not entitled to qualified immunity for the complained of conduct.
94. Defendants were at all times relevant herein, policymakers for and thus Defendants in that
capacity established policies procedures, customs, and/or practices for Richland County
School Board meetings.
95. Defendants developed and maintained policies, procedures, customs, and/or practices
exhibiting deliberate indifference to the constitutional protections of individuals as outlined
herein, which were moving forces behind and proximately caused the violations of
Plaintiff’s constitutional protections and federal rights as set forth herein and in the other
claims, resulted from a conscious or deliberate choice to follow a course of action from
among various available alternatives.
96. Defendants maintained a policy, practice and/or custom of tolerating harassment towards
women and choosing not to train or supervise board members regarding their behavior
during board meetings.
97. But for Defendant’s School Board’s policies, practices and/or customs of tolerating
harassment towards women and choosing not to train board members, Plaintiff never would
have suffered from sexual harassment at the hands of Defendant Devine and Plaintiff would
not have suffered the damages outlined herein.
98. Upon information and belief, Defendant School Board’s policies, practices, customs,
and/or supervisory indifference of Defendant Devine were motivated by a discriminatory
intent against women and/or Defendant School Board has tolerated long standing,
department wide discrimination towards women.
99. Defendants have developed and maintained long-standing, department wide customs,
policies, procedures, practices, and/or failed to properly train and/or supervise their
employees in a manner amounting to deliberate indifference to the constitutional

protections of Plaintiff. Furthermore, the policies, customs, procedures, insufficient
training, and/or practices were motivated by a discriminatory intent as outlined herein.
100. The deliberately indifferent training and supervision provided by Defendants resulted from
a conscious or deliberate choice to follow a course of action from among various
alternatives available to Defendants and were moving forces in the constitutional and
federal violations complained of by Plaintiffs.
PRAYER FOR RELIEF
WHEREFORE, the Plaintiffs pray judgment against the Defendant as follows:
i. Award all such actual, general, special, compensatory, and consequential
damages, including damages for emotional distress, humiliation, loss of
enjoyment of life, and other pain and suffering on all claims allowed by law
in an amount to be determined by the trier of fact;
ii. Award punitive damages on all claims allowed by law against the individual
Defendants and in an amount to be determined at trial;
iii. Issue a declaratory judgment, under 42 U.S.C. § 1983 declaring Defendants’
conduct unconstitutional;
iv. Award Plaintiff reasonable fees and costs pursuant to U.S.C. § 1988 and
any other applicable provisions of law; and
v. Award such other relief as the Court deems just and proper.
[signature page to follow]

Respectfully submitted,
LAW OFFICE OF TYLER RODY, LLC
S/Tyler Rody
Tyler Rody, Bar No. 104238
661 E. Main St.
Spartanburg, SC 29302
(864) 381-7969
(864) 670-5636 – Fax
[email protected]
Attorney for Plaintiff
August 19, 2024
Spartanburg, SC

Lawsuit Filed Against Jamie Devine, Richland One School Board

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ELECTRONICALLY FILED - 2024 Aug 19 4:31 PM - RICHLAND - COMMON PLEAS - CASE#2024CP4005067

STATE OF SOUTH CAROLINA IN THE COURT OF COMMON PLEAS

COUNTY OF RICHLAND CASE NO.: 2024-CP-40-

Jamie Devine, in his official and individual

LAW OFFICE OF TYLER RODY, LLC

COUNTY OF RICHLAND CASE NO.: 2024-CP-40-

vs. (Jury Trial Requested)

Jamie Devine, in his official and individual

1. Plaintiff Ali De La Cruz, hereinafter referred to as “Plaintiff,” is a resident of Richland

County, South Carolina.

2. Defendant Jamie Devine, (Defendant Devine) is a resident of Richland County, South

3. Richland One Board of School Commissioners, (hereinafter Defendant School Board) is

JURISDICTION AND VENUE

part, in Richland County, South Carolina.

to the United States Constitution.

6. The above allegations are hereby incorporated as if fully stated herein.

One (hereinafter Richland One).

objective criticism of Defendant School Board’s and Richland One’s actions.

scheduled public school board meeting held by Defendant School Board.

Plaintiff’s participation in the public segment, Defendant Devine took multiple

inappropriate, “upskirt” photographs of Plaintiff without her knowledge or consent while

County School District 1.

school board member during a school board meeting.

embarrassment, and other damages that will be outlined in this Complaint.

crime of moral turpitude and he is individually liable.

FOR A FIRST CAUSE OF ACTION

22. 42 U.S.C. § 1983 provides that:

for purposes of 42 U.S.C. § 1983.

protections to be free from retaliation for the exercise of protected speech.

government and/or engaged in protected speech by speaking at Defendant School Board’s

meetings, which were public forums.

school board meeting and by distributing those photographs to others.

taking of inappropriate “upskirt” photographs of Plaintiff by Defendant Devine.

at future School Board meetings.

protections to be free from retaliation for the exercise of protected speech.

scope of his official duties or employment.

practices exhibiting deliberate indifference to the constitutional protections of citizens,

various available alternatives.

standing, department-wide customs, policies, procedures, practices, and/or failed to

properly train and/or supervise its employees/ members in a manner amounting to

deliberate indifference to the constitutional protections of Plaintiff and of the public.

in the constitutional and federal violations complained of by Plaintiff.

FOR A THIRD CAUSE OF ACTION

reasonably and not to cause them unnecessary harm.

negligent, reckless, and/or willful by taking inappropriate upskirt photographs of Plaintiff

and distributing them to others.

Plaintiff and constitute a crime involving moral turpitude.

happiness, suffered emotional distress, pain, discomfort, mental anguish, alteration of

action under the South Carolina Tort Claims Act.

FOR A FOURTH CAUSE OF ACTION

a. Choosing not to adequately train personnel;

b. Choosing not to adequately manage personnel;

c. Choosing not to adequately supervise personnel;

d. Choosing not to enforce its policies and procedures;

harassing, intimidating, and/or illegal purposes; and

f. In other such particulars that may be found in discovery and/or trial.

and incorporated into this cause of action.

FOR A FIFTH CAUSE OF ACTION

then distributed the photographs to others in an attempt to harass, humiliate, intimidate,