Last month, Village of Tinley Park shelled out $2.5 million as a direct result of Connolly’s malfeasance. They are suing her to recoup this money.
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In May 2016 …..With little discussion, the Racine City Council approved hiring a Chicago suburban planner who had been suspended from her present position as the city’s new community development director.Connolly will start May 9 in Racine and make a salary of $115,480, said Racine City Administrator Tom Friedel. That’s a 2.7 percent pay increase from her last Tinley Park salary of $112,399.
19. Eventually, Connolly’s scheme was discovered and the Plan Commission voted to table the application for The Reserve and sent the application back to the Planning Department for further review.
20. On March 22, 2016 citizens of the Village of Tinley Park filed a lawsuit against the Village, requesting that the court void the Text Amendments.
21. On May 17, 2016 the Village of Tinley Park rescinded the Text Amendments.
22. Subsequent to the Village sending Buckeye’s application back to the Planning Department, Buckeye filed a federal lawsuit against the Village for, among other claims, discrimination under the Fair Housing Act. Thereafter, the United States also filed a federal lawsuit against the Village for discrimination under the Fair Housing Act.
23. Had Connolly not schemed to change the Legacy Code without the Village’s knowledge, the Village would not have been sued by Buckeye or the United States.
24. Had Connolly not schemed to change the Legacy Code, she could have devoted her time to attracting developments to the Village which complied with the Legacy Code, or worked with the Village to develop amendments to the Legacy Code that could help development while not destroying one of the major intentions of the Legacy Plan, namely commercial development. Amy Connolly resigns to take a job in Racine, Wisconsin
25. On February 17, 2016, the Village placed Connolly on leave, with pay, pending a review of her dealings related to the Text Amendments and her handling of the application for The Reserve. Case: 1:17-cv-03271 Document #: 1 Filed: 05/01/17 Page 5 of 7 PageID #:5 6
26. On or about May 6, 2016, Connolly resigned from her position as the Village’s Director of Planning.
27. On May 9, 2016, Connolly began her new job as the City of Racine, Wisconsin’s Development Director. Connolly breached her fiduciary duties to the Village
28. As a management-level employee, Connolly was a fiduciary of the Village.
29. As a fiduciary of the Village, Connolly owed the Village duties of care, loyalty and good faith.
30. In addition, Connolly also knew about the Rules of Conduct/Code of Ethics contained in the Village Personnel Manual. Connolly signed documents on multiple occasions acknowledging her receipt of the Personnel Manual.
31. Section 4.1 Rules of Conduct/Code of Ethics of the Personnel Manual states, in relevant part that “Employees of the Village must adhere to the following standards…[including]…[b]e[ing] honest and trustworthy in all they say and write.”
32. Notwithstanding Connolly’s duties and responsibilities as a management level employee and fiduciary of the Village, Connolly engaged in a pattern of willful, deliberate conduct that was adverse to the Village’s interests, violated Village policies, procedures and Rules of Conduct/Code of Ethics, and was intended solely to benefit Connolly’s self-interest.
33. Specifically, Connolly acted dishonestly and made numerous misrepresentations to the Village and its employees regarding changes to the Legacy Code.
34. Connolly engaged in this misconduct for her own personal gain and to the detriment of the Village in order to protect her job and promote her self-interest. Case: 1:17-cv-03271 Document #: 1 Filed: 05/01/17 Page 6 of 7 PageID #:6 7
35. During Connolly’s employment with the Village, the Village paid Connolly’s salary and benefits in consideration for Connolly’s faithful and loyal performance.
36. Without the Village’s knowledge, from at least April 2015 until her voluntary resignation on May 6, 2016, Connolly was in fact an unfaithful, disloyal employee.
37. As a result of Connolly’s misconduct, the Village has been damaged in the amount of the total compensation that the Village paid to or on behalf of Connolly from at least April 2015 until her voluntarily resignation on May 6, 2016.
38. As a result of Connolly’s misconduct, the Village has been damaged in the amount it was forced to expend to defend against and then settle a federal lawsuit filed by Buckeye against the Village, and defend against a lawsuit filed against it by the United States. WHEREFORE, the Village requests that this Court enter judgment in its favor and against Connolly in an amount in excess of $75,000 plus punitive damages sufficient to punish Connolly for her wrongful conduct and to deter others from such conduct, to grant the Village its attorneys’ fees and costs and to grant the Village such further relief this Court deems just.
PLAINTIFF DEMANDS TRIAL BY JURY
Respectfully submitted, VILLAGE OF TINLEY PARK, ILLINOIS