Revised Investigative Report on City Officials

INVESTIGATIVE REPORT ON THE
DIVERSITY, EQUITY & INCLUSION
OF CITIZENS OF SPRINGFIELD MO
(Revised)
An extensive examination of and detailed report on the conduct
of the Springfield, Missouri Mayor's Commission on Human Rights
& Community Relations, its Commissioners, the Springfield Director
of Diversity, Equity & Inclusion, Taj Suleyman, City Council members
and Mayor of Springfield, with recommendation for the impeachment
or removal by quo warranto, of one or more public officials from office.
PRESENTED TO:
Missouri Attorney General
Springfield, MO Mayor Ken McClure;
Springfield MO, City Council Members;
Springfield, MO Human Rights Commission & Community Relations;
Springfield, MO City Manager Jason Gage;
Springfield, MO Deputy City Manager, Maurice Jones; and
Springfield, MO Director of Diversity, Equity & Inclusion Taj Suleyman
By Christopher Cross, M.A., D.S.P., C.M.A. (ret)
Legal_Guardian77@yahoo.com
February 16, 2024

TABLE OF CONTENTS
Councilwoman Heather Hardinger's statement..............................................................................ii
Councilman Craig Hosmer's statement..........................................................................................iii
Code of Ethics Requirements........................................................................................................iv
Executive Summary........................................................................................................................1
Tuesdays with Council Meeting......................................................................................................2
Springfield (MO) Inclusion Survey (2020) Report...........................................................................4
Mayor's Initiative On Equity & Equality 2021 Report.......................................................................5
KC Star Article, April 5, 2023...........................................................................................................8
Personal Testimony.........................................................................................................................9
Mayor's Commission on Human Rights & Community Relations Website.....................................11
Missouri Sunshine Laws & Conduct of Commissioners..................................................................12
Third-party nonprofit interceptors or participants in public governmental
business & electronically transmitted communications...................................................................15
Commission's Complaint Procedures.............................................................................................18
City Code as it relates to the Mayor's Commission
on Human Rights & Community Relations.....................................................................................21
Concealment of commission's meeting minutes............................................................................25
Commission's Meeting, January 17, 2024.....................................................................................26
Commission's Meeting, February 12, 2024...................................................................................28
Springfield's Five Pillars of Change...............................................................................................36
City Council Appropriation Authority..............................................................................................40
Conclusion.....................................................................................................................................41
i

“I think it’s really important that we not only have a committee
to provide feedback as our community continues to adapt to
these changes, but that we’re also tracking our progress over
time so we know where we started and where we’re going,”
Springfield City Councilwoman Heather Hardinger, as
reported in Springfield Daily Citizen online media outlet,
'Springfield City Council Adopts North Star For
Navigating Equity and Equality' (May 2, 2022).
https://sgfcitizen.org/government/springfield-city-council-adopts-north-star-for-navigating-equity-and-equality/
This investigative report demonstrates that where we were in 2021. with the Mayor's Initiative
on Equity & Equality panel envisioning a better Springfield, is not where we are currently at in 2024.
ii

But if we don't have some concrete examples of what we're
doing today that we know we can put into practice. . .
Councilman Craig Hosmer, 'Tuesdays with Council Meeting”
January 30, 2024, discussing the city's housing priorities
This investigative report presents numerous shovel ready issues that requires the city council's
immediate attention as part of establishing the city's housing priorities.
iii

ARTICLE IV, DIVISION I, § 2-161
CODE OF ETHICS
(a). Policy; objectives.
(1). The public judges its government by the way
board members conduct themselves in the posts
to which they are appointed. The people have a
right to expect every board member to conduct
himself in a manner that will tend to preserve
public confidence in and respect for the board on
which he serves. Such confidence and respect can
best be promoted if every board member will
uniformly:
(a). Treat all citizens with courtesy, impartiality,
fairness and equality under the law; and
(b). Avoid both actual and potential conflicts
between his private self-interest and the public
interest.
iv

EXECUTIVE SUMMARY
This investigative report is limited to examining and reporting on the activities, agendas and conduct of
the Director of Diversity, Equity & Inclusion, Taj Suleyman and commissioner's serving on the Mayor's Commis-
sion on Human Rights & Community Relations.
This report discusses the January 30, 2024, 'Tuesdays with Council' meeting on the subject of housing
priorities, as well as both the 2020 and 2021 reports on the diversity, equity and inclusion priorities, concerns
and objectives that Springfield citizens and the Mayor's Initiative on Equity and Equality expressed.
It is the unwavering belief, position and avocation of the author, of this report, that housing priorities are
tied directly into the duties, conduct and outcomes of the Mayor's Commission on Human Rights and Commu-
nity Relations and Taj Suleyman, as their duties and conduct directly impact the vitality of neighborhoods, the
quality of place, access to housing, personal and public safety, and economic opportunities.
Finely, this report discusses the contributing factors that the Director of Diversity, Equity & Inclusion, Taj
Suleyman, engages in, that aids and/or abets the illegal and/or unlawful, unethical and dereliction conduct of
Commissioners', which further perpetuates violations of state and federal laws and duty of care, their breaches
of ethical obligations, and puts the lives, safety, health and/or welfare of Springfield citizens in danger.
It is the unwavering belief, position and avocation of the author, of this report, that conduct of Taj Suley-
man is wholly incompatible with and summarily contradicts the housing priorities identified during the Tuesdays
with Council meeting, on January 30, 2024. The result of his conduct creates tangible adverse effects on public
trust and confidence for Taj Suleyman's ability and willingness to be an effective city leader.
As a direct or proximate result of this report; the allegations made and documentary evidence that gives
support to such, and both the conduct engaged in and the tangible adverse effects imposing on the citizens of
Springfield, it is the author's position, belief and avocation that all Commissioner's be impeached and that Taj
Suleyman be terminated form his employment. Moreover, the failure or refusal to do so constitutes deliberate
indifference, gross negligence or a reckless disregard for the civil rights of Springfield citizens.
A copy of this report is provided to the Missouri Attorney General for consideration of exercising statu-
tory right and authority to file a Writ of Quo Warranto to remove one or more individuals from his, her or their
public office or appointed position, by court order. See e.g., State of Missouri Ex INF. Andrew Bailey, Attor-
ney General v. Kim Gardner (Case No. 2322-CC00383) (seeking a court order to remove a public official
from her office for, among other things, dereliction in performing duties, engaging public safety and impeding or
preventing the proper administration of justice).
THE REST OF THIS PAGE IS INTENTIONALLY LEFT BLANK
1

TUESDAYS WITH COUNCIL MEETING
On January 30, 2024, members of the Springfield, Missouri City Council engaged in their Tuesdays with
Council meeting, to discuss whether or not to make housing issues a standalone legislative priority, in a three-
part agenda.
Part One:
Part one entailed council members answering the following three statement:
A city council housing priority must have ___________ in the description
A city council housing priority must have ___________ as an objective.
A city council housing priority must not or should not have __________ as an objective.
Council members gave their written answers on yellow, blue, and pink Post-It Note paper, respective to
the aforesaid individual statements.
Councilman Brandon Jensen questioned whether the answers council member wrote would be read or
whether the floor was open for general discussion. Although the reply given by Councilwoman Horton was that
the individual answers could be read out loud, no effort to do this was made.
Councilwoman Heather Hardinger got out of her seat to read the individual council member responses
from the board, where the Post-It Notes were placed, so she could see the actual individual responses given.
Despite these clear cues for a reading of the actual responses to be done in the public meeting, Coun-
cilwoman Horton continued to fail or to refuse to read or have the responses read out loud. Mayor McClure as-
serted that a general conversation was the direction to take rather than reading the responses out loud.
By virtue of this, Councilwoman Horton and Mayor McClure effectively or essentially made the interac-
tive portion part meaningless, and a waste of time.
As such, the author of this report had to file a public records request to obtain the Post-It Note re-
sponses, to read the responses of each council member and Mayor McClure.
Part Two:
Part two entailed formulating the drafted description.
Councilwoman Monica Horton provided the following description, as an example:
“A dedication to improving all existing housing stock by closing the gaps in code
enforcement and expanding property incentives, property reinvestment incentives
offered by the city of Springfield, while also increasing housing options and access.”
City Manager Jason Gage pointed out that, under the city's current economic vitality plan, housing is di-
vided into: (1) quality of place, (2) economic vitality and (3) public safety.
Councilman Jensen and Councilwoman Horton recommend removing housing priorities out of the eco-
nomic vitality plan, to make housing a standalone legislative priority instead. No consensus was reached.
The overall focus of the meeting was on making home ownership a more viable and available option,
which will only benefit the privileged and city employees through tax funded stipends.
2

Part Three:
Part three entailed discussing the specific objectives of the housing plan. Councilwoman Horton gave
the following four objectives:
1. Improving housing code enforcement by such things as rental property
inspections, landlord licensing, and expansion of reinvestment incentives;
2. Improving affordable housing opportunities, creating public trust funds to
benefit organizations providing homes to impoverished individuals and
people who are homeless, and funding multifamily home development;
3. Update and adopt land use city codes that allow for inclusionary zoning,
creative transitional emergency and permanent housing; and
4. Supporting quality access to rental housing by landlord training and
risk mitigation and addressing tenant rights such as right to council in
eviction cases and eliminate source of income discrimination.
No consensus was reached on adopting any specific objectives. Rather, the consensus was to send the
matter to a committee, which Mayor McClure suggested will be the Community Involvement Committee, to iron
out the specific objectives. to present to the City Council.
Mayor Ken McClure commented at timestamp 47:33, that when discussing specific housing objectives,
public input is needed, in order for the council to consider and weigh all sides of the issues and the proposed
priority objectives.
3

SPRINGFIELD (MO) INCLUSION
SURVEY (2020) REPORT
See https://www.springfieldmo.gov/DocumentCenter/View/50681/Springfield-Inclusiveness-Survey
In 2020, the City Council and the Mayor's Commission on Human Rights & Community Relations both
designed and distributed the Springfield (MO) Inclusion Survey, which presents eight questions for Springfield
citizens to answer. Dr. Gloria J. Galanes, Ph.D., and Missouri State University Professor Emerita, wrote the fi-
nal report for distribution.
The report points out, on p.3, the survey period was from January 21, 2020 to March 2020, but since
each person or organization receiving the survey were encouraged to distribute it to others, it is impossible to
determine exactly how may people and organizations received the survey. The report does point out that 2,276
responses were turned in and factored into the final report.
Ultimately, the survey sought to determine the perceptions of Springfield citizens and entities in exactly
how inclusive the City of Springfield is, to-wit, those responding asserted that “Springfield is very inclusive, 249
(12.22%); somewhat inclusive, 812 (39.86%); not very inclusive, 646 (31.73%); not inclusive, 267 (13.11%); or
had no opinion/not applicable, 63 (3.09%).”
The report points out that among the top responses received, “[r]espondents called for more diversity of
all kinds (racial, ethnic, age-related, class, sex, gender, sexual orientation, and disability)” Id., and that “the city
needs to solicit the opinions of diverse members and actually listen to those opinions.” Id. Moreover, that the
“[l]ack of diversity is fostering an environment where people are subconsciously discriminating in addition to
purposefully [discriminating] (sic).” Id.
Specific responses received can be summarized into two categories. The first is to diversify leadership
across the board in the public and private sectors. Second, that city officials need to actually listen to and take
public input serious, rather than blowing off and ignoring, or patronizing, those who attempt to be part of and
participate in their local government. Id., at Pp.6 and 7.
In the Tuesdays with Council meeting at timestamp 54:15, Councilwoman Hardinger stated, “I think that
we have a sense of urgency in developing objectives that like truly need the quality of place that we've been
talking about for so many years. . . But also I think that, you know, we owe it to citizens who have been waiting
for some of this infrastructure to be put in place.” This shows a history of failing or refusing to listen and to act.
The author, of this report, asserts that the Mayor's Commission on Human Rights & Community Rela-
tions consistently demonstrates Commissioner's are grossly derelict in actually listening to public input and tak-
ing public input serious especially when receiving constructive criticisms about how it operates and their fail-
ures that are harming members of the public.
4

MAYOR'S INITIATIVE ON EQUITY
AND EQUALITY 2021 REPORT
See https://www.springfieldmo.gov/5443/Mayors-Initiative-on-Equity-and-Equality
The final report of the Initiative on Equity & Equality panel points out, “Springfield Mayor Ken McClure
and City Council voted unanimously in 2021 to create the Mayor’s Initiative on Equity and Equality to further
the City’s ongoing efforts to ensure an equitable environment that celebrates diversity and inclusion.” Id., on
p.1.
The panel existed for one-year. The panel represented “different personal and professional lived experi-
ences, different sectors of the community, and various cultural backgrounds.” Id. The final report was issued to
City Council and Mayor McClure, in March 2022.
The panel defined the terms diversity, equity, and inclusion to mean:
Diversity encompasses the entire human experience. Diversity is the wide
spectrum of unique lived experiences that each individual possesses,
expresses, and contributes.
Equity is promoting justice, impartiality, and fairness within the procedures,
processes, and distribution of resources by institutions or systems. Tackling
equity issues requires an understanding of the root causes of outcome
disparities within our community and society as a whole. Inclusion is how we
make diversity work.
Inclusion is the creation and support of an environment that not only accepts
but celebrates differences by leveraging diversity to make stronger decisions
for the greater good. Inclusive diversity is equally respectful of and embraces
the unique qualities of each person.
The panel identified and established specific principles the City needs to engage in, by the following:
➢ Seeking and listening to diverse thoughts respectfully;
➢ Fostering a culture of mutual learning through continual dialogue and education;
➢ Developing awareness of our own existing biases;
➢ Understanding, valuing, and respecting diversity;
➢ Cultivating inclusive partnerships to increase intentional and effective collaboration;
➢ Welcoming diverse voices and advocating for the underrepresented and the disenfranchised;
➢ Identifying and removing diversity, equity, and inclusion barriers;
➢ Refining policies and implementing practices to protect the rights of every member of our com-
munity;
➢ Inspiring, modeling, and promoting diversity, equity, and inclusion excellence; and
➢ Honoring individuals and organizations that demonstrate accountability for fostering an inclusive
community
By virtue of the January 30, 2024, 'Tuesdays with Council' meeting and Councilwoman Hardinger's
statements, at timestamp 54:15, it is evident City Council has not implemented the above principles consistent
with the responses that Springfield citizens shared in the 2020 Springfield (MO) Inclusion Survey.
5

Notwithstanding the aforesaid, in spite of the Mayor's Commission on Human Rights & Community Re-
lations being an active co-participant in conducting the 2020 Springfield (MO) Inclusion Survey, Commissioners
have been grossly derelict in performing their duties as prescribed by Article IV, Division 4, § 2-223(1),(2),(4)–
(6) of the City Code.
6

KANSAS CITY STAR MEDIA ARTICLE ON
MISSOURI COMMISSION ON HUMAN RIGHTS
See https://www.kansascity.com/news/politics-government/article273959450.html
On April 5, 2023, the Kansas City Star online media outlet published its investigative article, 'How a dys-
functional Missouri Human Rights Commission slows discrimination lawsuits'.
The article discusses that while the state human rights system is designed and intended to address and
resolve complaints of discrimination of protected classes, the system has become incredibly dysfunctional and
even derelict in performing its statutorily required duties.
The result, as the article points out, is that complaints are taking longer than 180 days to process and
investigate, just to determine if probable cause exists. The article also points out one complainant had to sue
the Missouri Human Rights Commission, to get her right to sue letter because of the extended time to process
and investigate her complaint.
This inflicts both ongoing tangible adverse harms and damages. It deprives due process and equality in
the application of law, and allows perpetrators of discrimination to continue operating illegally and/or unlawfully.
The report also points out that the state Commission suffers from the lack of manpower and resources
needed in its intake and investigative processes. As a result, the Missouri Human Rights Commission needs
municipalities to help receive, investigate and resolve complaints of discrimination of protected classes.
By local municipalities helping the state Commission, it shortens the length of time required to process
and resolve complaints; whether by administrative means or issuing the right to sue letter. It enables onsite in-
spections to be done by local officials in quicker time frames, and it permits in-person interviews to be done by
local officials.
Without municipalities becoming state certified to receive and process, investigate, and resolve claims
of discrimination, then the state will not recognize what is done locally. This means the complaint is subjected
to a duplication of services and processes, which compounds the harms and damages suffered.
On January 29, 2024, the author, of this report, emailed the website link of the Kansas City Star article
to the City Council, Mayor McClure, Chairwoman Charity Jordan, of the Mayor's Commission on Human Rights
& Community Relations, along with its Commissioner's, Chase Snider and Mike Garton. The point of doing this
was to convey the importance for local officials to collaborate with state officials, to resolve complaints.
On February 12, 2024, the Commissioner's of the Mayor's Commission on Human Rights & Community
Relations voted to not pursue any effort for any Commissioner to be state certified. Their rationale is that be-
cause City Council will not allocate funding to hire an investigator and because Commissioner's are volunteers,
they should not become state certified to help receive, process, investigate and resolve complaints.
There are nine (9) Commissioners on the Mayor's Commission on Human Rights. DEI Director Taj Su-
leyman informed this author, by electronic mail, only four (4) Commissioner's attended the February 12, 2024
meeting. The entire meeting was conducted by Zoom live-stream. This author attended that meeting.
By their vote of 4–0, Commissioner's decided, without a quorum and without voter approval, to repeal
or amend their duties in Article IV, Division 4, § 2-221 of the City Code, to collaborate with state, federal and
municipal agencies. In other words, to help investigate and resolve discrimination complaints.
In doing this, Commissioners did not act in the public's best interest and they appear to have violated
their prescribed duties pursuant to Article IV, Division 4, § 2-223(1),(2),(4)–(6) of the City Code.
7

AUTHOR'S PERSONAL TESTIMONY
On April 29, 2023, I filed my complaint with the Missouri Commission on Human Rights, of discrimina-
tion because of disabilities, in my previous residential dwelling, against my now former landlord,
On August 4, 2023, I moved out of my former residential dwelling in Springfield because allegedly, my
former landlord and its property management company refused to permit me to install a wheelchair ramp.
On August 14, 2023, I then filed my second complaint with the Commission on the basis of having been
constructively evicted from my former residential dwelling because of the disability-based discrimination.
On October 16, 2023, state law forced my former landlord to pay me double the amount of my security
deposit because my landlord did not return it to me within required thirty days from the date of my move out.
On February 2, 2024, the Commission finely sent me the formal charge of discrimination because of my
disabilities involving the wheelchair ramp.
On February 2, 2024, the Commission also finely sent me the formal charge of constructive eviction of
my previous residential dwelling.
Under city ordinances my complaint constitutes alleged violations of Chapter 62, § 134(2) of the City
Code, in that of disability-based discrimination in the terms and conditions of my rental dwelling, which resulted
in my allegedly being constructively evicted.
Under state and federal laws, my complaint constitutes alleged violations of 42 U.S.C. § 3604(b) and/or
(f)(1)(A) and/or (3)(A) and/or (B) and/or § 3617, as well as Mo. Rev. Stat. § 213.040.1(2).
In Klossner v. IADU Table Mound MHP, LLC, No. 21-3544 (8th Cir. 2023), the
Eighth Circuit Court of Appeals held that the Fair Housing Act requires
reasonable accommodations in the terms and conditions of the residential dwelling
for individuals with a physical disability. The Court explicitly pointed out that the
reasonable accommodations would include a tenant using a service animal and the
landlord or the property management company installing handicap parking spaces.
As such, it also includes permitting a tenant to have, enjoy and to use a wheelchair
ramp at their residential dwelling providing the tenant pays all financial costs and
restores the property to its original condition if the landlord or property management
company stipulate this requirement.
I assert that because of the alleged conduct of my former landlord and its property management com-
pany, I have allegedly suffered both non-economic damages, harassment, emotional distress and irreparable
harms, and economic damages in excess of one hundred thousand dollars ($100.000.00).
I assert that because of the alleged conduct of my former landlord and its property management com-
pany, I was forced to buy a house. As such, I alleged that my former landlord and/or its property management
company is/are liable for the total costs of my mortgage loan, plus other relevant additional costs.
It took a little over nine months for the Missouri Human Rights Commission to send me the formal
charge for discrimination because of disabilities. The Commission was required to send me the formal charge
within six months instead.
It took twelve days short of six months for the Commission to finely send me the formal charge of con-
structive eviction and thus, pushing the limits of the 180 day process time that state law imposes.
8

The two aforesaid formal charges were finely filed, but only after I had to argue with the state attorney
for the Commission and because the Missouri Attorney General's Office agreed with me, and instructed the at-
torney to file the charges and issue me my right to sue letters.
Among the arguments the state Commission made for not investigating my complaints, is that it lacks
the needed resources and manpower to travel to Springfield and inspect my former residential dwelling specific
to the location that I requested to install the wheelchair ramp.
Apparently, conducting this investigation by simply and merely looking at the Google Street View map is
deemed insufficient to conduct a proper state investigation, even though and in spite of my providing the state
Commission with the Google Street View map screen shots, when I filed my complaint on April 29, 2023.
Although the Springfield Mayor's Commission on Human Rights had the resources and manpower to do
an onsite inspection of my former residential dwelling and because it held subpoena power pursuant to Article
III, Chapter 62, § 143 of our Charter, as well as being authorized to conduct a public or private hearing with my
right to present evidence, it would have been more beneficial to file my complaint locally.
That said, I did not find any case laws showing state and/or federal courts recognize and accept a find-
ing of discrimination based only on city ordinances such as Article III, Chapter 62, § 134(2) of the City Code.
And because the Mayor's Commission on Human Rights and Community Relations is not state certified, I
could not risk using a local investigative remedy for my discrimination complaints. See Yellow Freight Sys-
tems, Inc. v. Mayors Comm'n., 791 S.W.2d 382 (Mo. Sup. Ct. en banc 1990).
Additionally, while an investigation by the Mayor's Commission on Human Rights & Community Rela-
tions would have greatly shortened the time for completion and disposition to be made, the processes used still
rely on and only use the “conference, conciliation and persuasion” practice.
Since my former landlord refused to return my $300.00 security deposit, that the landlord was forced by
state law to pay me double the amount, logic and common sense dictate the landlord will not pay me, in ex-
cess of $100,000.00, without a court order. And because the Mayor's Commission on Human Rights and Com-
munity Relations is not state certified, then it cannot issue me right to sue letters for my state law claims.
Insofar as the time frames involved. If, for some reason, a person waited until the 60th day to file his or
her complaint, as Article III, Chapter 62, § 62-140 of the City Code stipulates complaints are to be filed, and be-
cause it would take up to thirty days for a local investigator to be assigned, and assuming it took the full ninety
(90) days allowed under Chapter 62, Article III, § 62-142 of the City Code to investigate, this puts the intake,
processing and investigative time period at 180 days and thereby forecloses the right to file the complaint with
the state.
The above time frames do not include the time it would take to pursue and use the due process hearing
that Chapter 62, Article III, § 62-143 of the City Code permits. It should also be pointed out that nowhere in §
62-143 is there any time period a hearing is required to be done, if the complainant requests a hearing.
It is only in § 62-142 that a time period is imposed. Under this ordinance, a hearing is required to be
held within 150 days from the date the complaint is filed but only if it is the investigator who is requesting the
hearing.
Using these time frames would be fine but for the fact Commissioner's with the Mayor's Commission on
Human Rights are not state certified. Thus, using the local investigative remedy, under current conditions, puts
people at high risk of having to sacrifice their state law rights and state law claims because Commissioner's on
the municipal level do not want to be state certified.
9

Therefore, from a piratical point of view, it was moot and a waste of time for me to file my complaints to
the Mayor's Commission on Human Rights & Community Relations. From a logical and logistical point of view,
it was extremely risky. And from a legal point of view, filing my complaint with this commission would not have
produce a viable and sustainable cause of action in a court of law, under city ordinances.
Therefore, in spite of it being in the public's best interest for the Commissioners and the Commission in
and of itself, to become state certified and far more beneficial to the public to have a viable local remedy to use
instead of the dysfunctional state system, Commissioner's decided to act on their own self-serving interest and
personal rebellion by refusing to become state certified.
With alleged economic damages of over $100,000.00 suffered and however novel the legal theory may
be, to sue a landlord for a mortgage loan to buy a house because renting another home was not a remedy that
was viable, the attitudes, conduct and dereliction of duties the Commissioner's engage in, made it impossible
to use the local remedies.
10

MAYOR'S COMMISSION ON HUMAN RIGHTS
& COMMUNITY RELATIONS WEBSITE
On January 5, 2024, and by solicitation of Commissioner Mike Garton, this author submitted his audit
report to the Commissioners on the website pages the Commission uses.
This author's audit report identifies numerous specific issues with the website such as, but not limited
to, the following:
1. Video's that do not comply with the Americans with Disabilities Act;
2. Video's that recommend victims beg their perpetrators, to exercise their rights;
3. Video's that suggest people with disabilities need to risk their personal safety;
4. Website links that do not work properly to retrieve and read documents;
5. Failing or refusing to identify the chair and vice chair of the commission;
6. Giving contradicting information on the rights of privacy, from one web page to another;
7. Failing or refusing to comply with state laws governing Safe-At-Home participants;
8. Failing or refusing to give proper and required information on religious discrimination;
9. Failing or refusing to give proper and required information on sexual harassment; and
10. Failing or refusing to disclose Commissioner email addresses explicitly being used for
the purpose of the Commissioners conducting public business.
At the time of this report being submitted, no changes have been implement on the website pages used
by the Commission.
This demonstrates a clear and overt lack of care about the issues, dereliction of duty to stop the issues
and the deliberate indifference to correcting the issues.
Moreover, it also demonstrates the apathetic and callus positions and attitudes of the Commission, the
Commissioners and city officials, to the needs of people with disabilities and the responsibility to taxpayers, as
they are paying the financial costs.
11

MISSOURI SUNSHINE LAWS
& CONDUCT OF COMMISSIONERS
Pursuant to Article IV, Division 4, § 2-221 of the City Code it holds that the Mayor's Commission on Hu-
man Rights and Community Relations, “shall function as a permanent part of the city government[]” and thus,
establishing that the commission operates under the color of law with purpose and intent to carry out and fulfill
municipal government business.
Pursuant to Article IV, Division 4, § 2-223 et seq., of the City Code, the Commission and Commission-
ers are charged with the prescribed duty to conduct investigations into discrimination because of a protected
class standing, and to collaborate with state, federal and municipal agencies.
Pursuant to Chapter 62, Article II, § 62-40 and Chapter 62, Article III, § 62-143, the Commission is given
subpoena powers and the right to, inter alia, enter private property for purposes of conducting investigations for
and on behalf of and in collaboration with the municipal government, involving discrimination because of a pro-
tected class status, in private housing and private employment matters.
Pursuant to § 2-223(7) and (8), the Commission is required to both collaborate with the City Council in
formulating and shaping public policy and legislative initiatives that “will aid in eliminating all types of discrimi-
nation based on race, creed, sex, handicap, age, national origin or ancestry, or any other basis of discrimina-
tion prohibited under chapter 62.”
Therefore, the Commission and its Commissioners are a governmental body even though Commission-
ers operate as volunteers because the term “governmental body” is not based on the individual or entity being
on the payroll of the local government. See Tipton v. Barton, 747 S.W.2d 325, 329 (1988). The Court pointed
out that in MacLachlan v. McNary, 684 S.W.2d 543 (Mo. App. 1984), it defined “governmental body” to mean:
By enactment of the 1982 amendment to Chapter 610, it is apparent
that the legislature intended to affect the entire administrative
decision-making process, not just the formal act of voting for the formal
execution of an official document. It is unnecessary that an entity have
binding authority for it to be subject to the Sunshine Law. It is within the
meaning of the law if its determinations affect the public. Id. at 538
(emphasis added).
Logic and common sense dictate that Commissioners will require communication tools to discharge and
carry out their prescribed duties, which includes city owned and city controlled electronic mail addresses, so as
to comply with Missouri Sunshine laws, while also safeguarding information from being intercepted.
Prior to Clean Missouri being voted and incorporated into the Missouri Constitution, private electronic
mails and whether they are subject to Missouri's Sunshine laws, was governed by Mo. Rev. Stat. § 610.025, as
such holds:
Electronic transmission of messages relating to public business,
requirements. —Any member of a public governmental body who
transmits any message relating to public business by electronic means
shall also concurrently transmit that message to either the member's
public office computer or the custodian of records in the same format.
The provisions of this section shall only apply to messages sent to two
or more members of that body so that, when counting the sender, a
majority of the body's members are copied. Any such message received
by the custodian or at the member's office computer shall be a public
record subject to the exceptions of section 610.021
12

After Missouri voters approved Clean Missouri, in 2018, the City of Wildwood, Missouri reported having
to figure out how it applies to private electronic mail addresses because city officials learned that they are “not
excluded from the state Sunshine laws designed to provide transparency in government.” See West News
Magazine, 'Wildwood city council continues to debate email policy' (February 13, 2020).
As Mayor Jim Bowlin pointed out on February 5, 2020, during a City Council meeting, “as we know now,
we are not able to prevent those [private] email addresses from being provided to those who request them
properly[,]” i.e., though a Sunshine law request.
https://www.westnewsmagazine.com/news/wildwood-city-council-continues-to-debate-email-
policy/article_c2fd3f2b-ad7b-5821-9488-4fcdbea95d77.html
Pursuant to the Missouri Secretary of State's Office “a public record is any “document, book, paper,
photograph, map, sound recording or other material, regardless of physical form or characteristics, [that is]
made or received pursuant to law or in connection with the transaction of official business[]” (emphasis
added).
Moreover, that “[a]n email is an example of a format or “physical form” per 109.210 RSMo, the same as
a punch card, paper letter, microfilm, etc. The physical form of the record is irrelevant, rather, it is the content of
the email, or any other record, that determines how long it must be retained” Id., as a public record subject to
the Missouri Sunshine laws.
See https://www.sos.mo.gov/CMSImages/LocalRecords/CommunicationsGuidelines.pdf
On January 19, 2024, Commissioner Jasmine Allen sent this author an electronic mail in the course of
this author addressing Commissioner's in matters of public governmental business. Commissioner Allen sent a
copy of her electronic mail to Commissioners Charity Jordan, Mike Garton, Chase Snider, Bob Roberts, Jamea
Crum and Rachel Naab.
Charity Jordan's privately created electronic mail address to conduct public governmental
Commission business is jorcha.745@gmail.com
Chase Snider's privately created electronic mail address to conduct public governmental
Commission business is chase.snider.hrcommission@gmail.com
Mike Garton's privately created electronic mail address to conduct public governmental
Commission business is mchrcr@mikegarton.com
Jasmine Allen's privately created electronic mail address to conduct public governmen-
tal Commission business is jallen68@me.com
Jamea Crum's privately created electronic mail address to conduct public governmental Com-
mission business is jsc1051@sbcglobal.net
Rachel Naab's privately created electronic mail address to conduct public governmental Com-
mission business is rachel.mchrcr@outlook.com and
Bob Robert's privately created electronic mail address to conduct public governmental Com-
mission business is bob@secondbaptist.org
13

As shown in the aforesaid West News Magazine published article, each and every one of the privately
created electronic mail addresses above, are subject to Missouri's Sunshine laws.
The above privately created electronic mail addresses use private electronic mail service providers who
are at substantial risk of or who have themselves been hacked or subjected to pinshing attacks.
The above privately created electronic mail addresses are themselves at substantial risk of being either
hacked, subjected to pinshing attacks, or suffering other computer related crimes.
The above privately created electronic mail addresses are used to transmit information, documents,
and other material or tangible things that may or do constitute closed records, protected health information and
other confidential information, which is then intercepted and transmitted by third-party private service providers.
The above privately created electronic mail addresses are used on private electronic devices such as,
but not necessarily limited to, personal laptop or desk top computers, personal tablets, personal iPhones and
other similar personal equipment, which then store documents downloaded from these privately created elec-
tronic mail addresses and are then subject to being read by others having access to those personal devices.
The above privately created electronic mail addresses are subject to being used on third-party privately
owned devices such as, but not limited to, an employer, a public library, a friend, spouse, family member or a
501(c)(3) religious organization, church or other nonprofit, who can intercept and monitor wire communications.
There are numerous issues arising by using unsecured, unregulated and privately created electronic
mail addresses to conduct public governmental business, and places private citizens at substantial and overt
risk of having their personal information and protected health information transmitted to third-parties and those
engaged in criminal activity.
14

THIRD-PARTY NONPROFIT INTERCEPTORS OR PARTICIPANTS
IN PUBLIC GOVERNMENAL BUSINESS & ELECTRONICALLY
TRANSMITTED COMMUNICATIONS
Pursuant to the January 19, 2024 electronic mail from Commissioner Jasmine Allen, an individual who
is identified as Bob Roberts was carbon copied on her electronic mail.
According to the Springfield Chapter of the NAACP, Spring 2018 edition, on p.4, Bob Roberts became a
Commissioner on the Commission, in 2018.
See https://sgfneighborhoodnews.com/wp-content/uploads/2018/04/SGFNNSpring18WEB.pdf
According to the Missouri Sports Hall of Fame website, Bob Roberts continued his active appointment
to the Commission as late as April 28, 2023.
See https://mosportshalloffame.com/honorees-announced-for-spring-sports-luncheon-june-7/
Each Commissioner is permitted to serve two – three year terms and thus, a grand total of six years.
In light of the two aforesaid publications, it reasonably appears the end of Bob Robert's term out period
is in 2024. Hence the reason that Jasmine Allen copied Bob Roberts on her January 19, 2024 electronic mail to
this author, as a reasonable inference can be drawn that Bob Roberts is an active Commissioner. If not, then
Commissioner Allen drew in an outside person to intercept electronically transmitted communications.
Therefore, there is reasonable cause to believe or a reasonable inference can be drawn, that when the
February 12, 2024 Commission meeting took place, there were a combined total of nine (9) Commissioner's on
the Commission.
According to the Linkedin website page for Bob Roberts, he has been a Pastor at the Second Baptist
Church in Springfield since 2001 to the present date and thus, well within the time period that Bob Roberts was
first appointed to serve as a Commissioner on the Commission.
See https://www.linkedin.com/in/bob-roberts-5264b77/
On December 14, 2023, Bob Roberts participated in an online publicized interview conducted by the
Public Broadcasting Service.
https://www.pbs.org/newshour/show/how-some-evangelical-leaders-are-combating-political-radicaliza-
tion-in-their-congregations
In the interview, Bob Roberts discusses that churches have become polarized, in part, because of being
involved in political activities. It is curiously odd therefore, that Bob Roberts uses the church's electronic mail
address to engage in conducting public governmental body business involving the Commission.
The privately created electronic mail address Bob Roberts' uses, belongs to, is used by and under the
control of a 501(c)(3) religious organization, Second Baptist Church.
Therefore, on all relevant dates and times, Second Baptist Church is and has been an active interceptor
of and participant in electronically wired communications from or to a public governmental body.
Such interceptions of the electronically wired communications gives Second Baptist Church the ability
to receive closed governmental records, personal and protected health information of Springfield citizens, and
privileged communications such that constitutes work product or attorney-client matters. It also gives Second
Baptist a strategic advantage to obtain inside information involving political matters and the ability to use that
information to lobby for or against specific legislation by and through, for example, Calvin Morrow.
15

On June 5, 2023, City Council called up and debated, by public hearing, Bill No. 2023-126, which holds.
TITLE: A resolution affirming City Council’s commitment to applying
the Five Pillars of Change detailed in the 2022 Mayor’s Initiative on
Equity and Equality Report to constituents from the LGBTQ+
community; and demonstrating City Council’s dedication to continued
collaboration with constituents from the LGBTQ+ community and all
citizens to improve the culture of inclusion and belonging in Springfield.
PURPOSE: To affirm City Council’s commitment to applying the Five
Pillars of Change detailed in the 2022 Mayor’s Initiative on Equity and
Equality Report to constituents from the LGBTQ+ community; and to
demonstrate City Council’s dedication to continued collaboration with
constituents from the LGBTQ+ community and all citizens to improve
the culture of inclusion and belonging in Springfield
A reasonable cause to believe or a reasonable inference can be drawn that Bob Roberts continued to
serve on the commission and continued to use the religious organization's electronic mail address, to engage
in, conduct, and participate in political activities of the Commission.
Chapter 62, Article IV, Division 1, § 2-223(8) of the City Code, explicitly authorizes the Commission to
engage in lobbying for or against specific legislation.
A Commissioner who uses his or her privately created electronic mail address belonging to, accessible
by and under the control of a religious organization, i.e., Second Baptist Church, automatically and immediately
draws the religious organization into the official business of the public governmental body.
Second Baptist Church has received the extraordinary ability and opportunity to intercept and read the
electronically transmitted communications on Bob Robert's electronic mail address, involving official public gov-
ernmental body business. It does not matter if Second Baptist Church has read any communication. It is good
enough that Second Baptist Church is permitted to wiretap, by intercepting the electronic communications.
Mo. Rev. Stat. § 542.402 (2017) holds:
1. Except as otherwise specifically provided in sections 542.400 to 542.422, a person is guilty
of a class E felony and upon conviction shall be punished as provided by law, if such person:
(1) Knowingly intercepts, endeavors to intercept, or procures any other person to
intercept or endeavor to intercept, any wire communication;
2. It is not unlawful under the provisions of sections 542.400 to 542.422
(3) For a person not acting under law to intercept a wire communication where
such person is a party to the communication or where one of the parties to the
communication has given prior consent to such interception unless such
communication is intercepted for the purpose of committing any criminal or
tortious act (emphasis added).
Bob Roberts cannot give Second Baptist Church permission to intercept wire communications involving
the official public governmental business of the Commission or the City: (he cannot give permission for Second
Baptist Church to intercept wire communications constituting closed government records, personal or protected
health information on Springfield citizens, privileged work product or attorney-client communications, or other
information that gives Second Baptist Church a strategical advantage to lobby for or against specific legislation
directly or through a PAC, person or other entity, to seemingly bypass IRS codes).
16

Permitting a religious organization to engage in wiretapping, by intercepting electronically transmitted
communications of a public governmental body such as, but not limited to, the personal or the protected health
information of a private Springfield citizen, may very well violate state and/or federal privacy rights. It may also
violate Missouri Safe-At-Home laws if the information intercepted involves a participant in that state program.
The same applies to third-party owned and controlled electronic mail addresses such as, but not limited
to, Gmail, Outlook, Sbcglobal, or a dot com internet domain name. Each is a third-party entity who has owner-
ship of, access to, and control over the electronic mail address used, which are regulated by individual Terms
of Service rules.
Gmail prohibits sending “unauthorized emails via open, third-party servers” and distributing confidential
information by email of another person without prior consent. Commissioner, Chairwoman Charity Jordan and
Commissioner Chase Snider both use Gmail electronic mail address accounts.
Outlook prohibits using electronic mail to engage in any illegal or unlawful activity. Commissioner Naab
uses an Outlook electronic mail address.
There are various email hosting service providers existing, which permit individuals to create private dot
com electronic mail address. Each has their own Terms of Service. Commissioners Mike Garton and Jasmine
Allen use a email hosting service providers.
Suffice to say, legitimate Internet and email hosting service providers will prohibit using electronic mail
addresses to engage in illegal and/or unlawful conduct. The City, Commission and Commissioners are ultra
vires to use, permit or require using private electronic mail addresses for conduct that violates any Terms of
Service, or that violates any state and/or federal law, rule or regulation.
17

COMMISSION'S COMPLAINT PROCEDURES
Pursuant to the Commissions website page discussing the specific complaint procedures that are to be
used in filing complaints of discrimination, the following is documented:
1. A complaint is filed in writing with the Commission Office;
2. A copy of the complaint is furnished the person and/or organization accused of
discrimination;
3. A committee of 2 commissioners is appointed by the Springfield Commission
Chairperson to investigate the complaint;
4. The investigating commissioners will usually meet with the complainant and
respondent and interview witnesses. However, the case can be dismissed
to jurisdictional limitations or non-cooperation from the complainant or
respondent. If commissioners issue a No Probable Cause finding or if there
is an Administrative Dismissal, all parties will be notified; and
5. The complaint can be settled at any time during this process. If probable cause
is determined by the investigators, there is an endeavor to eliminate the
discriminatory practice by conference, conciliation, and persuasion.
(All proceedings from Step 1 through Step 5 remain confidential.) (emphasis
added
See https://www.springfieldmo.gov/828/Resolving-a-Complaint
The above complaint processes and procedures present several issues by contradicting information on
the complaint intake form and by failing or refusing to disclose rights and limitations. For example:
1. Nowhere in the above complaint processes and procedures are members
of the public informed about the due process rights and limitations in Chapter
62, Article II, § 62-40 and Chapter 62, Article III, § 62-143 of the City Codes.
2. The above complaint processes and procedures at ¶ 5, purport that any and
and all proceedings from Step 1 through 5 are confidential. The actual intake
form notices up a complaint, that the complaint can be disclosed to the public.
https://www.springfieldmo.gov/FormCenter/City-Managers-Office-17/Intake-Information-Form-Human-Rights-
Com-463
As a result, the information provided about the complaint processes and procedures is deceptive and/or
misleading; deprives or abridges due process.
Both the City and the Commission owe a duty of care to provide accurate, truthful and consistent facts
and information to the public about the complaint procedures, the rights and obligations of complainants, and
the scope, ability, authority and limitations imposed on any investigation conducted and its outcome.
On the intake form itself, complainants are required to acknowledge and accept that their personal and
confidential information is subject to disclosure and distribution under Missouri Sunshine laws. This constitutes
a release of information consent waiver, that is intended to protect the City and Commission from liability.
18

However, Mo. Rev. Stat. § 589.669 (2018) holds:
Upon demonstration that an applicant has been accepted into the program by
the secretary, government agencies and the courts shall accept the designated
address as a program participant's address when creating a new public record
unless the secretary has determined that:
(1) An agency has a bona fide statutory or administrative requirement for
the use of the program participant's address or mailing address and is unable
to fulfill its statutory duties and obligations without the address; and
(2) The program participant's address or mailing address shall be used only
for those statutory and administrative purposes and shall not be made
publicly available (emphasis added).
On January 17, 2024, this author explicitly recommended to the Director of Diversity, Equity & Inclusion,
Taj Suleyman and his assistant, that a box be put on the intake form to give notice about a complainant being a
Safe-At-Home participant. To date, however, no corrective actions have been made.
The Commission and DEI Director demonstrate and communicate their utter disregard for the personal
and physical safety of victims of crime and people fearing for their safety, and act with deliberate indifference to
their duty of care, to make the necessary and required changes to the intake form.
Moreover, the Commission and DEI Director demonstrate and communicate their dismissive attitude for
public safety and their duty to act in the public's best interest.
The Commission's and DEI Director's aforesaid conduct and attitudes constitute misconduct, malfea-
sance, misfeasance, and/or nonfeasance, which encourages, permits and/or rewards criminal activity.
It is immaterial and wholly irrelevant that the intake form asserts personal information “could be subject
to disclosure, if requested under the Sunshine Law” (emphasis added) because the threat and coercion tactics
used, are sufficient enough to chill a complainant exercising his or her rights.
1. Absolutely no corrective actions have been taken to ensure Safe-At-Home
state laws are not violated;
2. The threats and coercion tactics are sufficient to cause a Safe-At-Home
participant to fear for his or her safety;
3. The requirement for a Safe-At-Home participant to waive his or her state
law rights, in itself, violates Safe-At-Home state laws; and
4. The requirement to waive state law rights is self-serving to shield the City
and Commission from liability for endangering Safe-At-Home participants.
The Missouri General Assembly saw fit to exercise its legislative authority to give victims of crime and
those who fear for their safety, special rights to conceal their true and actual residential, work, school and mail-
ing addresses. The City and Commission are ultra vires to abrogate those state rights and state-created liber-
ties.
Even assuming a Safe-At-Home participant can upload the Safe-At-Home participant identification card
by the online portal, it does not guarantee the upload is successfully received, properly stored and retained and
that the information and record will not be deleted, altered, misplaced or destroyed at a later time.
19

Providing a check box on the intake form that the complainant is a Safe-At-Home participant, ensures
that notice is given for the entire length of time that the intake form exists.
As the Court in Yellow Freight Systems, Inc. pointed out, Mo. Const. art. VI, § 19(a) only confers that
authority to a constitutional charter city, which the legislature has authority to give. Id., 791 S.W.2d 382 at 385.
The Missouri General Assembly used the substantive predicate term of “shall”, in § 589.669(2), to un-
ambiguously communicate and dictate that the personal and confidential information of Safe-At-Home partici-
pants shall not be disclosed or distributed to the public and thus, is wholly exempt from state Sunshine laws.
While the visibly tone deaf position of the City and Commission using the intake form to require or force
Safe-At-Home participants to waive their rights and liberties is disconcerting, the subsequent failure or refusal
of the City and Commission to remedy the issues, is gravely irresponsible, reprehensible, and unconscionable.
Moreover, it constitutes misconduct, malfeasance, misfeasance, and/or nonfeasance, and the dereliction of the
duty of care to protect public safety.
20

CITY CODE AS IT RELATES TO THE
MAYOR'S COMMISSION ON HUMAN RIGHTS
& COMMUNITY RELATIONS
For purposes of this investigative section, the City Code focus is on Chapter 62, Article II, § 62-31 to §
62-105, (Fair Employment Practices); Chapter 62, Article III, § 62-131 to § 62-151, (Fair Housing Practices);
and Chapter 62, Article IV, Division 4, § 2-221 to § 2-223 (Commissioner Duties & Powers).
Chapter 62, Article IV, Division 4, § 2-221 holds:
There is hereby established an advisory board to be known as the Springfield
Mayor's Commission on Human Rights and Community Relations. Such
commission shall function as a permanent part of the city government. The
commission shall foster mutual understanding and respect among all racial,
religious and ethnic groups of the city, discourage and prevent discrimination
against any such group or its members, cooperate with federal, state and
municipal agencies and nongovernmental organizations having like or kindred
functions, and make such investigations and studies in any field of human
relations as, in the judgment of the commission, will aid in effectuating its
general purpose.
Chapter 62, Article IV, Division 4, § 2-222 requires members of the commission to be nominated and
appointed by the City Mayor with the approval of City Council. The Commissioners are required to hold public
meetings at a minimum of nine (9) times each calendar year. The Commission is required to be representative
of Springfield communities. And Commissioners are to elect a Chair and Vice Chair, to preside over the public
meetings, assign Commissioner's to perform various duties.
Chapter 62, Article IV, Division 1, § 2-223
The powers and duties of the commission established by this division shall be to:
(1) Foster, though community effort or otherwise, good will, cooperation
and conciliation among the groups and elements of the inhabitants of this
community.
(2) Formulate and carry out educational programs that will aid in eliminating
and preventing all types of prejudice and discrimination based on race, creed,
sex, handicap, age, national origin or ancestry.
(3) Receive, hear and investigate complaints and initiate its own investigations,
and report to the city council on the following:
a. Racial, religious and ethnic group tensions, prejudice, intolerance,
bigotry and discrimination, and any breach of the peace or disorder
occasioned thereby.
b. Practices of discrimination against any person in employment, recreation,
education, housing and other phases of public welfare because of race,
creed, sex, handicap, age, national origin or ancestry, or any other basis of
discrimination prohibited under chapter 62
21

(4) Initiate and conduct voluntary surveys, assemble pertinent data, hold hearings,
issue such publications and such reports of investigations and research as, in its
judgment, will tend to minimize or eliminate prejudice, intolerance, bigotry,
discrimination, breach of peace or disorder, or tend to promote good will.
(5) Create such advisory committees and subcommittees as, in its judgment, will
aid in effectuating the purposes of this division and to empower it to study the
problems of prejudice, intolerance, bigotry and discrimination, and breach of
peace or disorder occasioned thereby.
(6) Enlist the cooperation of all racial, religious and ethnic groups, community, civic,
labor and business organizations, fraternal and benevolent associations, veterans'
organizations and other groups in educational campaigns and programs devoted
to teaching the need for eliminating group tensions, prejudices, intolerances (sic),
bigotry and discrimination, and breach of peace and disorder occasioned thereby.
(7) Make recommendations to the city council concerning the development of
policies and procedures that will aid in eliminating all types of discrimination
based on race, creed, sex, handicap, age, national origin or ancestry, or any
other basis of discrimination prohibited under chapter 62.
(8) Recommend to the city council legislation to aid in carrying out the purposes of this
division.
(9) Hold public hearings and request the attendance of witnesses when the commission
deems it necessary or advisable to accomplish its purposes.
Due to the various but certainly very important duties Commissioner's are prescribed by Charter, as laid
out above, in § 2-223, the public has a reasonable expectation that Commissioner's will possess qualifications
suitable to the duties required and conduct themselves in proper manner. For example, but not limited to:
1. Be thoroughly competent in all duties and powers of the commission;
2. Jealously safeguard and proactively protect Springfield citizens from discrimination;
3. Conduct competent, just, proper and prudent investigations into discrimination claims;
4. Proactively collaborate with state and federal agencies in investigating discrimination;
5. Conduct public meetings, produce reports, and proactively collaborate with city council;
6. Proactively engage in legislative lobbying efforts to ensure the commission has the tools
it requires to effectively, efficiently, and consistently discharge its duties and powers; and
7. Engage in educational campaigns and actively participate in council meetings on matters
in the commission's purview, duties, objectives and powers.
Article XV, Chapter 15, § 15-5 of our Charter, also requires Commissioners be Springfield residents for
a minimum of two years; be qualified voters; reside in Springfield during their term of office; serve without any
compensation; and they are required to take the same oath of office as members of the City Council. Pursuant
to § 15-5, Commissioners are also required to be politically nonpartisan while serving their terms.
The prescribed duties in § 2-223 leave no room to doubt the capacity in which Commissioner's serve on
the Commission and the specific duties they are to perform means Commissioners are not only an invaluable
resource and remedy to combat discrimination but also, they are an intrinsic part of the municipal government.
22

Article XV, Chapter 15, § 15-5 imposes a duty on the City Council and Mayor, to ensure that candidates
for the Commission are properly suited and qualified. While § 15-5 does not define any specific process that a
candidate is to undergo to prove qualifications, a reasonable inference can be drawn that the process would be
the same or substantially similar to Mo. Rev. Stat. § 78.350 (1939), which holds:
hold examinations for the purpose of determining the qualifications of applicants
for positions, which examination shall be practical and shall fairly test the fitness
of persons examined to discharge the duties of the position to which they seek to
be appointed.
To sufficiently demonstrate necessary qualifications to be appointed a candidates for the Commission
should, at the bare minimum, demonstrate the following qualifications:
1. Sufficient intellectual competence on what constitutes discrimination
of a protected class;
2. Sufficient intellectual competence about the duties and powers of the
Commission, as a whole body and of the individual Commissioners;
3. Sufficient intellectual competence about the City ordinances governing
the Commission and its duties, functions, focuses and powers;
4. Sufficient intellectual competence about state and federal laws that
interact with or govern privacy rights of complainants; and
5. A demonstrated willingness to serve faithfully in his or her appointment
to the Commission and to uphold and fulfill his or her oath of office.
Unlike other boards and commissions, the importance for Commissioners to posses needed intellectual
competence in specific areas is because Commissioners are investigating violations of law and ordinances, to
dramatically and profoundly affect the constitutional rights of others. It is not a trivial capacity Commissioners
serve in, and both their capacities and duties cannot be treated with a casual or dismissive attitude.
It is therefore of paramount importance and requirement that Commissioners be properly trained for the
positions, capacity and duties they serve. However, as long as Commissioners rebuke and rebel against their
being properly trained and state certified, then Commissioners will continue to be derelict in their duty of care
and refuse to act in the public's best interest.
It is inexcusable, reprehensible, and constitutes malfeasance, misfeasance, and/or nonfeasance for the
Commissioners to fail or refuse to comply with their prescribed Charter duty in Article IV, Division 4, § 2-221, to
collaborate with municipal agencies, Missouri Human Rights Commission and the U.S Department of Housing
and Urban Development by being state certified to help conduct investigations.
The conduct of the Commissioners and all of them is made even more unconscionable by having been
provided a copy of the April 5, 2023, Kansas City Star investigative article showing the the need to be certified
by the state to help the Missouri Human Rights Commission, investigate discrimination complaints. Their blind
eye and deaf ear conduct constitutes a willful and wanton disregard to protect people in protected classes.
The Kansas City Star investigative article provides verifiable and credible findings of facts and it gives
clear and undeniable evidence that the Missouri Human Rights Commission needs the help of local municipali-
ties to conduct just, proper and prudent investigations.
Chapter 62. Article IV, Division 4, § 2-221 holds in relevant part that. “[t]he commission shall . . . coop-
erate with federal, state and municipal agencies” (emphasis added) to leave no room to doubt it is not a discre-
tionary duty Commissioners can fail or refuse to perform or otherwise sidestep or undermine.
23

Although not specifically defined in the aforesaid section, the common definition of the term “cooperate”
in context of having an inter-agency collaboration, is to work jointly together to achieve the same outcome.
In other words, it is more than just having the same goal, as it requires a joint partnership to achieve the
goal by working hand-in-hand with each other by becoming state certified to conduct investigations.
Therefore, it is an egregious dereliction of prescribed duties for the Commission and its Commissioners
to arbitrarily, capriciously or unreasonably and blatantly decide to refuse to be state certified.
This decision is counterproductive to, contradicts, and prevents joint inter-agency collaboration to com-
bat discrimination and thereby not only address individual violations of civil rights, but also systemic issues that
arise when perpetrators are permitted to continue their illegal and/or unlawful conduct.
It is a senseless and unnecessary adversarial posturing and positioning that substantially pits one gov-
ernment entity against the other. And it most assuredly, substantially and grossly fails or refuses to show that
the Commission and Commissioners are truly acting in the public's best interest.
The asserted predicate for this decision, as Chase Snider expressed on January 30, 2024, is that since
Commissioners are volunteers and the City Council is not providing the funding needed to hire an investigator,
then Commissioners should not have to devote their personal time to conducting investigations for the City.
However seemingly rational and justified the asserted argument is, every Commissioner consciously
chose to knowingly, willing and intentionally fill out and submit an application to be appointed to serve on the
Commission and actually knew, should have known, were required to know or could reasonably foresee that in
doing so, it would require them to devote their personal time conducting investigations.
Therefore, it is extremely reprehensible, unconscionable, and extraordinarily irresponsible for those on
the Commission to cry foul now, especially because Chapter 62, Article IV, Division 4, § 2-223(7) and (8) allow
and even compel Commissioners to proactively recommend policy changes and legislation needed to improve
and empower Commissioners to discharge their duties and functions and exercise their powers.
The conduct of the Commissioners is tantamount to a two-year old child throwing a tantrum because he
is too lazy and flat out refuses to ask for the piece of candy that he wants.
Being a Commissioner is not about having a bullet point to put on a resume that gives bragging rights to
claim what great, important and powerful human beings they are to decide the rights and liberties of people.
24

CONCEALMENT OF COMMISSION'S
MEETING MINUTES
In the course of this author investigating the Commission, Commissioners and their respective conduct
and parts, this author found the Commission and the City knowingly, willfully, intentionally and maliciously fail
or refuse to publish Commission public meeting minutes. This occurred throughout the 2023 calendar year and
thus far until otherwise changed, it also includes January and February 2024.
Upon discovering such, this author brought the issue to the attention of the City Clerk, Anita Cotter, the
Director of Diversity, Equity & Inclusion, Taj Suleyman and his assistant, Adriana Failla. The City Clerk did not
respond. Both Taj Suleyman and Adriana Failla purport they have no clue why this has occurred and that they
are supposedly “looking into it”. A reporter from National Public Radio verified the issue and thereupon, filed a
formal open records request for the missing meeting minutes.
In review of the City's website scheduling calendar web page, the following was discovered:
January 2023: No meeting held.
February 2023: No meeting held.
March 2023 to July 2023: Meeting held. No minutes published.
August 2023: No meeting held.
September 2023 to December 2023: Meeting held. No minutes published.
January 2024. Meeting held. Publication of minutes still pending
February 12, 2024. Special meeting held. Publication of minutes pending.
February 21, 2024. Regular order meeting scheduled to occur.
Taj Suleyman purported that not publishing the meeting minutes is not intentional and is supposedly an
isolated incident. This author informed Taj Suleyman the incidents have occurred on a habitual basis that it is a
custom, pattern or practice of intentionally concealing open public records. Thereafter, Taj Suleyman asserted
a posturing for himself and other City officials, of having lawyered up, to refuse to provide further information.
25

COMMISSION'S REGULAR ORDER MEETING
JANUARY 17, 2024
On January 17, 2024, the Commission conducted its regular order meeting, which was done in-person,
with Commissioner Chase Snider appearing and voting by and through Zoom live-stream.
Pursuant to Mo. Rev. Stat. § 610.020.3, the Commission may establish guidelines as to the recording of
its public meetings. The Commission does not have any known, published, or otherwise disclosed guidelines.
Throughout the January 17, 2024, meeting, Commissioner Chase Snider appeared by and voted from
his participation by the Zoom live-stream.
Pursuant to the meeting agendas, the Commission permits public comments immediately following the
minutes being read and adopted, but before any other agenda item is brought up. As such, the public is is not
permitted to speak on agenda items and no public hearing occurs on any agenda items to be voted on.
During the January 17, 2024, meeting, the agenda item “Meeting with the
Mayor Update” was brought up. Taj Suleyman counseled Commissioners
on this subject. This author raised his hand to speak. Chairwoman Charity
Jordan called on this author to speak. Taj Suleyman publicly reprimanded
this author for speaking on the agenda item. Taj Suleyman also publicly
reprimanded Chairwoman Jordan by stating she was not permitted to call
on this author to speak. Taj Suleyman is not a presiding officer, he is not a
Commissioner, he does not have any voting power, and he does not have
any investigatory authority. He is only the liaison between the City and the
Commission, in his capacity of the Director of Diversity, Equity & Inclusion.
During the meeting, Chase Snider addressed the Commission. He disclosed that Commissioner Mike
Garton and himself recommend against the Commission having Commissioners become state certified to con-
duct discrimination investigations.
Chase Snider explained the Commission does not have the resources or manpower because the City
Council will not appropriate needed funding to hire an investigator. He and Mike Garton also asserts that due to
Commissioners being volunteers, Commissioners should not have to interrupt their personal time conducting
discrimination investigations – that is the duty of a paid employee investigator to do instead.
Towards the end of the January 17, 2024, meeting, Taj Suleyman counseled the Commissioners about
making a decision whether or not to petition the Mayor and City Council to repeal or amend Chapter 62, Article
IV, Division 4, § 2-221 and § 2-223(3) et seq., of the City Code – the investigatory ordinances.
Pursuant to § 2-223(8), the Commission has the right and duty to lobby the Mayor and the City Council
for legislation but only insofar as, that “aid in carrying out the purposes of this division.”
Lobbying for legislation that abrogates the duties § 2-221, to collaborate with state, federal and munici-
pal agencies. is flatly contrary and wholly inconsistent with purposes and the duties in § 2-223(3) and (7).
Lobbying for legislation that abrogates the duties in § 2-223(3) to investigate discrimination is both flatly
contrary to and wholly inconsistent with the purposes and duties in § 2-221 and § 2-223(7).
Furthermore, it is a breach of the duty in Article IV, Division I, § 2-161(b), which prohibits engaging in
“actual and potential conflicts between his private self-interest and the public interest.”
During the January 30, 2024, Tuesdays with Council” meeting, Councilman Hosmer wrote on his pink
Post-It Note response, to housing priority objectives, “Self regulation complaint based enforcement.”
26

On February 16, 2024, this author sent Councilman Hosmer and electronic mail asking him to explain
his aforesaid response. That same day, Councilman Hosmer sent this author a reply, which holds:
what I meant was we should do primary enforcement and not just wait for a
complaint or hope that property owners will self-regulate the bad one will not
unless there is primary enforcement of all of our laws and regulations.
Pursuant to § 2-223(3) the Commission is authorized to initiate its own discrimination investigations and
not wait for a complaint to be filed. However, the position of the Commissioners is that they should not have to
conduct investigations because they are volunteers and do not have he funding to hire an investigator. As such
the Commissioners put their own self-interest above public interest, in violation of § 2-161(b).
In 2021, the Mayor's Initiative on Equity & Equality panel was established and based on recommenda-
tions the panel made in its 2022, report, the Springfield Five Pillars of Change was created. Among the many
other recommendations the panel made is that of:
➢ Identifying and removing diversity, equity, and inclusion barriers
➢ Refining policies and implementing practices to protect the rights
of every member of our community
In 2020, the Commission and the City, conducted a survey of Springfield citizens and business entities,
to determine just how diversified and inclusive the City is, and what issues Springfield citizens believe need to
be addressed. Among the top issues is that of discrimination because of a protected class.
Despite the visible cues and expressed views of the public, the Initiative panel, and what the Five Pillars
of Change is suppose to achieve, the Commission and Commissioners are tone deaf and have blind eyes, as
their self-interest are more important than the public's interest.
They will not willingly resign, so they must be impeached. If City Council refuses to impeach them, then
they must be removed by court order pursuant to a Petition for Quo Warranto.
27

COMMISSION'S SPECIAL MEETING
FEBRUARY 2, 2024
On the main website page for the commission, it is announced that the commission conducts monthly
meetings on the third Wednesday at 5:30 PM in the West conference room at the Bush Municipal Building.
See https://www.springfieldmo.gov/805/Mayors-Commission-Human-Rights
The January 17, 2024, Commission meeting agenda asserts the next regular order business meeting is
to be held on the third Wednesday, February 21, 2024.
On February 8, 2024, this author sent Commissioner Mike Garton an electronic mail asking for the date
of the next Commission meeting. This author pointed out the City's website did not show the Commission was
having any meetings throughout the entire month of February.
On February 12, 2024, a reporter called this author at 2 o'clock in the afternoon. In the course of talking
about the Commission's meeting agendas, the reporter inadvertently discovered the Commission was actively
holding a meeting at that moment by Zoom live-stream. The reporter and this author were surprised about this.
On February 15, 2024 – one week after the above February 8, 2024 electronic mail and three days after
the February 12, 2024 meeting – Mike Garton sent this author an electronic mail, which holds in relevant part:
We were working on changing the meeting night from Wednesday and
they did a poll, but I have not seen the results of it. They posted a
notice for a virtual meeting that happened over Zoom on Monday. They
posted the notice last week per requirements. I was out of pocket on
Monday and was unable to attend.
On February 16, 2024, the City published that the Commission will conduct a regular order meeting on
the third Wednesday, February 21, 2024.
The February 21, 2024, meeting agenda shows that the minutes for the February 12, 2024, meeting will
be read for approval and adoption.
_______________________________________________________
On February 8, 2024, this author sent Mike Garton an electronic mail pointing out that, as of that date,
the City's scheduling calendar website page did not show any Commission meetings for February 2024.
On February 12, 2024, the Commission held a meeting, which was conducted by Zoom live-stream.
The published agenda is not labeled as a “special meeting” and the agenda items are only regular order
business.
On February 16, 2024, the City scheduling calendar website showed that the Commission will conduct
a second meeting on February 21, 2024.
The published agenda is not listed as a “special meeting” and the agenda items are only regular order
business.
The published agenda for the February 21, 2024 meeting, shows the minutes for the February 12, 2024
meeting will be put to the Commissioners to approve, that the February 12, 2024 meeting was regular order.
28

The City is a home rule charter city, see 791. S.W.2d 382 at 383. Missouri Constitution art. VI, § 19(a)
gives the City only those powers which the legislature is authorized to grant. Id., at 385.
Mo. Rev. Stat. § 610.020.2 (2004) requires that:
Notice conforming with all of the requirements of subsection 1 of this
section shall be given at least twenty-four hours, exclusive of weekends
and holidays when the facility is closed, prior to the commencement of
any meeting of a governmental body unless for good cause such notice
is impossible or impractical, in which case as much notice as is reasonably
possible shall be given.
Therefore, because § 610.020.2 stipulates notice of public meetings must be given “at least twenty-four
hours” (emphasis added) in advance, the legislature has given the City powers to decide if more than 24-hour
notice is required – it is only that the 24-hours notice is the minimal notice time required.
Chapter 62, Article IV, Division 4, § 2-221 to § 2-223 of our City Code, are wholly silent about notice re-
quirements for public meetings conducted by the Commission.
Article XV, § 15-1 to § 15-20 of our City Charter is wholly silent on any notice requirements of any public
meetings to be scheduled and held.
In Yellow Freight Systems, Inc., 791. S.W.2d 382, the Missouri Supreme Court frequently drew from
and relied on different sections of our City Code, City Charter, and state laws, to determine the Commission's
roles, duties and authority.
Therefore, drawing from Article II, § 2-31(a) and (b), which are the notice requirements City Council is to
abide by for regular order and special meetings, the same notice requirements would reasonably apply to and
govern public meetings the Commission schedules and holds.
For special meetings, § 2-31(b) only relates to notice given to the members of the public governmental
body. Therefore, public notice of special meetings is governed by § 610.020.2, to require at least 24-hours.
For regular order meetings, § 2-31(a) requires that a minimum seven (7) day public notice is to be given
when there is a deviation from the regular order meetings that are normally conducted.
A five (5) day public notice was given for the February 21, 2024 meeting, but only a 24-hour notice was
given for the February 12, 2024, meeting. Both were regular order, but one was done as a special meeting.
Under the argument that the February 12, 2024 meeting held an urgent or dire need, to constitute being
a bona fide “special” meeting, then the notice requirements in § 2-31(b) and § 610.020.2, govern.
Under the argument that the February 12, 2024 meeting was actually regular order, then notice require-
ments in § 2-31(a) required a seven (7) day public notice to be given instead.
The February 12, 2024 meeting agenda shows that only regular order business was conducted. Since
it was only regular order, it does not qualify to be classified as a special meeting with an urgent or dire need.
Even assuming, argumentatively, that a second meeting was needed for February 2024, it sill does not
and would not qualify as a special meeting with an urgent or dire need because it was a regular order meeting.
Because the February 12, 2024 meeting agenda shows only regular order business was the focus of
discussion and action, the 24-hour notice given did not comply with § 610.020.2 requirements to give “as much
notice as is reasonably possible” when scheduling a meeting that deviates outside of the norm.
29

According to published meeting agendas, the discussion of the Commission's role has occurred since
at least December 13, 2022. Therefore, the February 12, 2024 meeting did not have an urgent or dire need.
As such, the Commission fails to show the agenda item of the Commission's role, i.e., investigations, is
a bona fide urgent and dire need, to warrant, rationalize and justify the special meeting on February 12, 2024.
In fact, none of the subjects on the February 12, 2024 agenda show there was any urgent or dire need
for a special meeting to be scheduled and conducted. It was all normal regular order business.
It is important to also point out the Commission's past documented history and customary behaviors, as
they speak louder than words, are irrefutable and enable a better examination of current behaviors, to occur:
In review of the Commission's meeting agendas for 2022 and 2023,
the Commission conducted what is called “retreat” meetings for
training in December 2022 and November 2023. However, never
once during both years did the Commission ever hold more than
one regular order meeting and never once did the Commission ever
conduct a “special” meeting.
Therefore, it is reasonable to believe and a reasonable inference can be drawn that the Commission or
City violated the requirements of § 610.020.2 and/or § 2-31(a) in the time requirement the notice is to be given.
The violation of Missouri's Sunshine laws is certainly no surprise, as it is habitual with the Commission
and the City:
From January 2022 to December 2022, meetings occurred every
month. The meeting agendas for every month are published. But
the minutes for every monthly meeting are not published.
For the year 2023, in the months of January, March, April, May, June,
July, September, November and December, meetings were held each
month. However, the minutes for those meetings are not published.
(No meeting occurred in February 2023 and August 2023)
For twenty-two (22) out of twenty-four months (24), the City and Commission knowingly, willfully and
intentionally violated Sunshine laws by habitually failing or refusing to publish meeting minutes. This shows the
existence of a well-established custom, pattern or practice of violating the law.
Therefore, it is wholly consistent with their well-documented past behaviors, that the Commission and
the City also violated Sunshine laws and city ordinance, in their failing or refusing to comply with notice require-
ments for the meeting held on February 12, 2024, because truthfully, it was a regular order meeting that was
deceptively held out as a bona fide special meeting.
_______________________________________________________
The subject issue of exactly how many people are serving as a Commissioner also needs discussion in
light of the number dictating how many Commissioners are required to constitute a quorum.
Pursuant to Article XV, § 15-5 of our City Charter, the Commission is to have no less than five (5) and
no more than fifteen (15) Commissioners.
Pursuant to § 15-5, one term consists of three-years. Commissioners are permitted to serve two terms,
and until such time as a successor is appointed and qualified.
30

The City website page for the Commission identifies eight (8) individuals appointed to the Commission,
in 2024, as follows:
Jasmine Allen Gail Herbert
Janea Crum Charity Jordan
Daniel Furtak Rachel Naab
Mike Garton Chase Snider
As previously discussed, the Springfield Chapter of the NAACP reports Bob Roberts was appointed as
a Commissioner in 2018. This puts the term out year in 2024, in Bob Roberts serving two – three year terms.
The Missouri Sports Hall of Fame asserts Bob Roberts continued to actively serve as Commissioner as
late as April 2023. This shows Bob Roberts was actively pursuing his combined full six (6) year term.
On January 19, 2024, Commissioner Jasmine Allen sent this author an electronic mail, and she carbon
copied Bob Roberts, which made Bob Roberts privy to the entire electronic mail chain.
According to a Google search, the City shows Bob Roberts with the term out date of October 1, 2024.
31

As shown above, the City does not identify Bob Roberts as a commissioner on the City's website page
for the Commissioners. However, this, in itself, is not conclusive proof that Bob Roberts is not a Commissioner.
This author sent Bob Roberts two electronic mails about the matters. However Bob Roberts continues,
at the present time, to knowingly fail or refuse to confirm or deny that he is an active Commissioner.
Therefore, until new credible evidence proves otherwise, it is reasonable to believe that Bob Roberts is
an actively serving Commissioner.
_______________________________________________________
In light of the aforesaid documented facts, a reasonable inference can be drawn and reasonable cause
exists to believe, at the present time, that a total of nine (9) Commissioner's are actively serving.
However, if we are to believe the City's website page listing the individual Commissioners, then there is
a total of only eight (8) commissioners.
_______________________________________________________
This author attended the February 12, 2024, meeting, which was conducted by Zoom live-stream in the
absence of the Commission recording and publishing an audio-video recording of the meeting.
At the time this author joined the meeting, Commissioner Chase Snider was speaking on the subject of
his and Mike Garton's recommendation that Commissioner's not become state certified to conduct discrimina-
tion investigations.
Pursuant to Mo. Rev. Stat. 78.712, when there are seven members to a governmental body, a quorum
of four members must be present to legally, lawfully and ethically cast, count, and accept votes made.
Under Robert's Rules of Order, when there are eight members to a governmental body, then a quorum
of five members must be present to legally, lawfully and ethically cast, count, and adopt votes made.
Pursuant to the Rules of Procedure for the City's Planning and Development Board, at § 2.5, a quorum
consist of five (5) members. The Planning and Development Board consist of eight (8) members identified on
the City's website. See https://www.springfieldmo.gov/921/Rules-of-Procedure
Upon Chase Snider concluding his statements, a motion was made and seconded to adopt the request
for Commissioner's to not be state certified. Votes were cast, counted and adopted. The motion passed.
On February 13, 2024, Taj Suleyman sent this author an electronic mail and identified a total of four (4)
Commissioners attending the February 12, 2024, Commission meeting:
Charity Jordan Chase Snider,
Jasmine Allen Gail Herbert
The motion passed 4–0 and thus, in the absence of there being the legally required quorum.
_______________________________________________________
The question now becomes whether the aforesaid Commissioner's were legally and lawfully permitted
to proceed in their scheduled meeting in and of itself, when there was no quorum existing – four Commission-
ers do not constitute a quorum.
32

In response to the question of whether members of a public governmental body can meet and discuss
public governmental body business outside an official public meeting, the Missouri Attorney General, Andrew
Bailey, responds with:
Under the Sunshine Law, a meeting takes place when a majority or
quorum of a public governmental body gathers to discuss or vote on
public business (§ 610.010(5), RSMo, and Colombo v. Buford, 935
S.W.2d 690 (Mo. App. W.D. 1996)). Therefore, if less than a quorum
of the public body meets to discuss public business, it is not a
“meeting” as defined under the Sunshine Law. However, the Sunshine
Law will apply to meetings of groups with less than a quorum when the
entity is deliberately attempting to evade the Sunshine Law. See,
Colombo, cited above. For example, a public governmental body may
not purposely meet in groups with less than a quorum to discuss public
business and then ratify those decisions in a subsequent public meeting.
https://ago.mo.gov/get-help/programs-services-from-a-z/sunshine-law/sunshine-law-faqs/#:~:text=Therefore
%2C%20if%20less%20than%20a,to%20evade%20the%20Sunshine%20Law.
The aforesaid four (4) Commissioners gathered and met under the guise of conducting an official public
meeting, as prescribed in the February 12, 2024 meeting agenda.
The Director of Diversity, Equity & Inclusion, Taj Suleyman admitted in his February 13, 2024, electronic
mail, that only four (4) Commissioner's attended the February 12, 2024, scheduled public meeting.
Therefore, on all relevant dates and times, the Commissioner's held actual knowledge, were required to
know, should have known or could otherwise see they did not have the legally required quorum to proceed.
Despite this, the Commissioner's proceeded to engage in, discuss, act and vote on public governmental
official business laid out and prescribed in the February 12, 2024 meeting agenda.
The Commissioner's knowingly, willfully, intentionally and maliciously engaged in the aforesaid conduct
with purpose of ratifying by votes, to summarily bar Commissioner's becoming state certified to investigate.
with purpose of ratifying by votes, their refusal to act in the public's best interest.
with purpose of ratifying by votes, to arbitrarily or capriciously amend or repeal Chapter 62, Article IV, § 221.
with purpose of ratifying by votes, to also arbitrarily or capriciously amend or repeal Chapter 62, Art. IV, § 223.
with purpose of ratifying by votes, their own self-interest, personal agendas, and individual whims.
The Commissioner's engaged in their aforesaid acts, omissions, conduct, deception, fraud, turpitude
and illegal, unlawful and unethical conduct, with the Director of Diversity, Equity & Inclusion, Taj Suleyman and
his assistant, Adriana Failla, direct, personal and interactive participation in the February 12, 2024 meeting.
_______________________________________________________
The question now turns to why. Why did the Commissioner's engage in such highly A-typical behavior in
scheduling and conducting a meeting under the false guise of having such urgency or dire need?
33

This author has directly, personally and consistently communicated with Commissioners by electronic
mail; putting pressure on them and, in very expressed terms, condemned their dereliction of duties, adversarial
efforts and unconscionable self-serving decision to not be state certified to conduct investigations.
This author has described the horrific physical, sexual and emotional abuse he suffered twelve-years of
his childhood, by people in positions of power with no viable recourse to stop the abuse.
This author has also pointed out that because the Commissioner's filled out and submitted an applica-
tion to be appointed to and serve on the Commission, if they are unwilling or unable to perform their duties and
serve the public's best interest, then they need to resign.
Therefore, this author has been exceptionally visible and consistently expressive in his condemnation of
the conduct, efforts, and agenda of the Commissioner's to put their own personal and private self-interest, ego
driven agenda, and individual whims before and contrary to the public's best interest.
Regardless if the meeting constitutes a special or regular order meeting, the Commissioner's waited un-
til Friday, February 9, 2024, to give only twenty-four (24) hours notice about the February 12, 2024.
The Commissioner's conduct is flatly, wholly and undeniably inconsistent with a very well-established
and very well-documented two-year behavioral history of never once before having ever conducted any
“special” meeting and never once before having had a second regular order meeting in the same month.
The purpose, design and intent in the Commissioner's doing so now – all of a sudden – was with intent,
design and purpose to impede or prevent transparency, evade Sunshine laws, and to impede or prevent this
author attending the meeting and thus, try to impede or prevent this author exposing their conduct.
The conduct of the Commissioner's, Taj Suleyman and Adriana Failla demonstrates and constitutes
their misconduct, malfeasance, misfeasance, and/or nonfeasance, violations of Article IV, Division I, § 2-161
(a)(1)(b) of our City Code, and violations of law.
Moreover, and more profoundly and grave is that the conduct of the Commissioner's, Taj Suleyman and
Adriana Failla constitutes abusing, neglecting and exploiting people in protected classes for their own personal
gains, ego driven image desires and their individual benefits. It is nothing short of a gross and exceptionally
evil, unconscionable and egregious abuse of power.
_______________________________________________________
Compounding the unconscionable gravity of the issues, violations of law, and tangible adverse effects
of their conduct is that Chapter 62, Article IV, Division 4, § 2-223(7) and (8) gave the Commissioner's the tools
they needed to fix whatever issues they believe impedes or prevents discharging their duties.
Chapter 62, Article IV, Division 4, § 2-223 holds, in relevant parts:
The powers and duties of the commission established by this division shall be to:
(7) Make recommendations to the city council concerning the
development of policies and procedures that will aid in
eliminating all types of discrimination based on race, creed, sex,
handicap, age, national origin or ancestry, or any other basis of
discrimination prohibited under chapter 62.
(8) Recommend to the city council legislation to aid in carrying out
the purposes of this division.
Where the Commissioner's believe and have argued that because they are volunteers and they do not
have the appropriated funding to hire an investigator, then § 2-223 mandated they engage the City Council.
34

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