Charles D. Collins filed suit in the U. S. Southern District Court of Mississippi (“SDCM”) on April 23, 2012, against his former employer, the Jackson Public School District (“JPSD”) for retaliation under Title IX after his participation in a complaint and subsequent investigation into disparities for JPSD female student-athletes.

While pursuing his suit, evidence emerged that then Callaway HS principal Clinton F. Johnson fabricated a document and used it to falsely accuse Collins of criminal acts. The JPSD concealed the accusations even after filing with the Jackson Police Department and terminating Collins’ employment.

Collins used the newly discovered evidence to amend his complaint in August 2013.  Because JPSD had no legal defense, the JPSD and SDCM conspired to fraudulently dismiss Collins' suit.

On February 14, 2014 (“Feb 14”), the JPSD purportedly filed a motion for summary judgment.  However, the memorandum (“Memo” or “Doc 69”) and exhibits (“Doc 69-1 to 69-13”) were not disclosed as required.  Instead, a copy of Collins’ deposition transcript (“Doc 69-1”) was docketed while Docs 69, a second 69-1, and 69-2 thru 69-13 were concealed 228 days by clerks Arthur Johnston and Robin R. Lowery in violation of 18 U.S. Code § 2076.

On September 30, 2014 (“Sept 30”), Judge Carlton W. Reeves (“Reeves”) issued an order dismissing Collins’ suit.  The Sept 30 Order (“Order”) does not lay out a factual basis for dismissal.  Reeves’ Order contains false statements and misrepresentations to deceive that JPSD attorneys KaShonda L. Day (“Day”) and JoAnne N. Shepherd ("Shepherd") made legitimate arguments in their Memo.

The Memo is fraudulent, the Memo’s certification by Day is false, and the Memo’s exhibits were all created after the 8:24 pm file stamp by SDCM. Two different Doc 69-1 were file stamped and removed from the SDCM docket. All criminal violations under 18 U.S. Code § 2071 and § 2076.

Additionally, the Memo and Order bare the same font, font size, page layout, use of language, capitalization, and there are seventeen matching sentences found within the first six pages of both set of documents.  Both appear written by the same person, misrepresent facts, and match other documents purportedly authored by and filed by attorney Day.

On September 28, 2015, counsel for Collins filed a 60(b)(6) motion to vacate the Order.  Reeves delayed almost one year before holding a hearing on August 17, 2016 (“Aug 17”). At the hearing, Reeves, law clerks Elissa Johnson and Alicia Netterville, Attorneys Day and Shepherd were late for reasons unknown. There, Reeves argued evidence for JPSD, refused Collins’ computer expert to make a record his findings, and denied the motion without reason.

The Aug 17 hearing transcript does not accurately reflect testimony: During one exchange between Reeves and Collins’ counsel, Reeves asked, to the amusement of his law clerks, “who are you blaming for the fraud?” but court reporter Cherie G. Bond edited out that exchange.

For Collins’ attempt to vacate Reeves’ Order under a 60(d)(3) motion in February 2018, the JPSD attorneys filed no answer. Despite this, Reeves delayed months, held no hearing, and denied the motion with prejudice without reason.

On appeal of Reeves’ denial, the Fifth Circuit threatened Collins with sanctions and ordered him to pay court cost instead of laying out a factual reason in its March 2019 decision.

Collins followed the judicial process; he did not lose this case!  A conspiracy was perpetrated by public officials! Here, falsified documents were sent via electronic and U.S. mail in both the Southern District Court of Mississippi and the Fifth Circuit Court of Appeals!

REQUEST that AG Merrick Garland and Assistant AG Kristen Clarke resolve this case. Call (202) 514-2000 and press #4 to leave a comment.

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VIDEO EVIDENCE OF FRAUD SCHEME (Click Part)

• False Court Filing (Part 1)
• False Court Filing (Part 2)
• False Court Filing (Part 3)
• False Court Filing (Part 4)
• Memorandum and Court Order (Part 5)

"Despite having not a shred of evidence of any nefarious conduct, he accused unnamed court personnel of knowingly engaging in a scheme of fraud . . . " 

-- DAVIS, HAYNES, and GRAVES, 5th Circuit Judges. (March 2019 Opinion)