A former senior civil service employee is seeking legal redress after alleging that municipal officials knowingly fabricated evidence to justify her dismissal, resulting in the loss of her employment, professional reputation, and future job prospects. The lawsuit, filed by Jakimah R. Dye in the United States District Court for the Northern District of Ohio on April 10, 2026, names the City of Cleveland as well as several individual officials—Matthew Cole, Dornat Drummond, Mark Griffin, Nicole Carlton, and unidentified John Does—as defendants.
According to the complaint, Dye had served more than thirteen years with the City of Cleveland in a classified civil service position before she was terminated following a motor vehicle accident involving a city-owned vehicle on February 17, 2024. The plaintiff alleges that after this incident, senior city officials constructed and advanced what she describes as a “demonstrably false timeline” regarding her disclosure about minors being present in the vehicle at the time of the accident. The complaint states: “Defendants constructed, adopted, and relied upon a demonstrably false timeline claiming that Plaintiff only disclosed the presence of minors in her vehicle after being confronted with a police report that did not yet exist and could not have existed at the time of her disclosure.”
Dye claims she fully cooperated with all post-accident procedures and voluntarily sent an email on February 22, 2024—before any police report was completed or released—clarifying details about the accident and acknowledging four children were present in the vehicle. She asserts this email was sent without prompting or confrontation by city officials. The complaint outlines: “Plaintiff sent the email without prompting, without being asked to do so… No City official had asked Plaintiff for any follow-up or additional information prior to her sending the email.”
The lawsuit further details that at no point during an investigatory meeting on February 21 was Dye confronted with any documentary evidence or accused of dishonesty. It also highlights that contemporaneous communications from Warrensville Heights Police Department confirm their accident report was not completed until February 23—after Dye’s voluntary disclosure.
Despite these facts, Dye alleges that city officials continued to advance what she calls a fabricated narrative through sworn testimony and disciplinary proceedings. She contends this narrative—that she became forthcoming only when documentary proof was imminent—was material to justifying her termination on grounds of dishonesty. The complaint states: “The charge of dishonesty… could not stand without the false characterization that Plaintiff became forthcoming only when she believed documentary proof was imminent.”
The legal filing describes how Dye’s supervisor was informed at the scene about children being present in the vehicle days before any disciplinary meeting took place. Nevertheless, according to Dye’s account, this information was omitted from internal reports and decision-making processes.
The complaint outlines multiple alleged violations: deprivation of procedural due process under federal law (42 U.S.C. § 1983), fabrication of evidence by government officials in violation of constitutional rights, deprivation of liberty interest due to stigmatizing public statements made during termination proceedings (so-called ‘stigma-plus’ claims), civil conspiracy among named defendants to deprive Dye of constitutional protections, and municipal liability under Monell theory for ratification or established custom leading to constitutional deprivations.
Dye asserts that both pre-disciplinary and post-termination processes were constitutionally deficient because they relied on allegedly fabricated facts despite available documentary evidence contradicting those facts. She further claims she was denied adequate notice or opportunity for representation during key meetings preceding disciplinary action.
In terms of relief sought from the court, Dye requests compensatory damages for lost salary (approximately $124,000 annually), benefits, pension contributions, reputational harm affecting future employment opportunities, emotional distress including anxiety and humiliation stemming from public findings against her character; punitive damages against individual defendants; injunctive relief restoring her employment; attorneys’ fees; costs; and other appropriate remedies.
Attorneys representing Jakimah R. Dye are not specifically named within this portion of the filing provided for review. No judge is explicitly listed in this document excerpt either. The case identification number is 1:26-cv-00860.
Source: 126cv00860_Dye_v_City_of_Cleveland_Complaint_Northern_District_Ohio.pdf
