Chs Fire Dept Lawsuit

ELECTRONICALLY FILED - 2023 Oct 12 12:39 PM - CHARLESTON - COMMON PLEAS - CASE#2023CP1005032
STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS

) FOR THE NINTH JUDICIAL CIRCUIT
COUNTY OF CHARLESTON ) CASE NO.: 2023-CP-10_______
)
GEORGE BOLOVIS, )
)
Plaintiff, ) SUMMONS
) (Jury Trial Demanded)
v. )
)
THE CITY OF CHARLESTON FIRE )
DEPARTMENT (THE CITY OF )
CHARLESTON); ANDREW (“KYLE”). )
WEBB, in his individual capacity; )
WILLIAM HAIGLER, in his individual )
capacity; KEVIN MORRIS, in his )
individual capacity; KEVIN CARTER, in )
his individual capacity; )
)
Defendants. )
____________________________________)
TO THE ABOVE-NAMED DEFENDANTS:
YOU ARE HEREBY SUMMONED and required to Answer the Complaint in this action,
a copy of which is herewith served upon you and to serve a copy of your Answer to said
Complaint on the subscriber at his office, Apostolou Law Firm, LLC, 3443 Rivers Avenue, North
Charleston, South Carolina, 29405, within thirty (30) days after the service hereof, exclusive of
the day of such service and if you fail to answer the Complaint within the time aforesaid, the
Plaintiff in this action will apply to the Court for the relief demanded in the Complaint and will
seek a default judgment against you.
APOSTOLOU LAW FIRM
/S/ Michael Thomas Cooper

Michael Thomas Cooper, SC Bar 100053
3443 Rivers Avenue
North Charleston, SC 29405
Ph (843) 853-3637
[email protected]
Attorney for Plaintiff
Dated: Thursday, October 12, 2023
North Charleston, South Carolina!
Page 1 of 16
STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS
) FOR THE NINTH JUDICIAL CIRCUIT
COUNTY OF CHARLESTON ) CASE NO.: 2023-CP-10_______
)
GEORGE BOLOVIS, )
)
Plaintiff, ) COMPLAINT
) (Jury Trial Demanded)
v. )
)
THE CITY OF CHARLESTON FIRE )
DEPARTMENT (THE CITY OF )
CHARLESTON); ANDREW (“KYLE”). )
WEBB, in his individual capacity; )
WILLIAM HAIGLER, in his individual )
capacity; KEVIN MORRIS, in his )
individual capacity; KEVIN CARTER, in )
his individual capacity; )
)
Defendants. )
____________________________________)
COMES NOW the Plaintiff, above-named, who would respectfully allege and show unto
the Court as follows:
PREFACE
1. As preface to the present legal action, Plaintiff is a former employee of the Charleston Fire
Department who sustained permanent hearing loss as a direct and proximate result of a
fellow fireman placing an explosive device underneath Plaintiff’s cot within the fire station,
a government building.
2. Plaintiff brings the present legal action, because Plaintiff firmly believes the residents and
taxpayers of the City of Charleston deserve a fire department worthy of our beautiful and
historic city.
3. Plaintiff believes and understands there is a culture of hazing, harassment, and hostility at
Page 2 of 16
certain fire stations within the City that drives away talented and highly qualified recruits
and fellow firemen. Within these fire stations there exists a good-ole-boy attitude and
mentality that is prioritized over the safety and well-being of the public. This culture is
known and tolerated by leadership within the City of Charleston Fire Department.
4. As a victim of such hazing, Plaintiff seeks to shed light on these problems and effect what
change this litigation might bring about.
PARTIES AND JURISDICTION
5. Plaintiff, George Bolovis (hereinafter referred to as “Plaintiff” or “Bolovis”), is a citizen and
resident of Charleston County, South Carolina. During all times relevant herein, Plaintiff
was an employee of the City of Charleston and the Charleston Fire Department.
6. Defendant City of Charleston is a municipal subdivision of the State of South Carolina with
its principal offices located in Charleston County, South Carolina. The City of Charleston
operates the Charleston Fire Department (hereinafter “CFD” or “Fire Department”), a
department within the municipal subdivision.
7. Upon information and belief, Defendant Andrew Webb (hereinafter “Defendant Webb” or
“Webb”) is a resident and citizen of Charleston County, South Carolina. Defendant Webb is
sued in his individual capacity, however, during all times relevant herein Defendant Webb
was an employee of the City of Charleston and the Fire Department.
8. Upon information and belief, Defendant William Haigler (hereinafter “Defendant Haigler” or
“Haigler”) is a resident and citizen of Charleston County, South Carolina. Defendant Haigler
is sued in his individual capacity, however, during all times relevant herein Defendant
Haigler was an employee of the City of Charleston and the Fire Department.
Page 3 of 16
9. Upon information and belief, Defendant Kevin Morris (hereinafter “Defendant Morris” or
“Morris”) is a resident and citizen of Charleston County, South Carolina. Defendant Morris
is sued in his individual capacity, however, during all times relevant herein Defendant Morris
10. Upon information and belief, Defendant Kevin Carter (hereinafter “Defendant Carter” or
“Carter”) is a resident and citizen of Charleston County, South Carolina. Defendant Carter is
sued in his individual capacity, however, during all times relevant herein Defendant Carter
11. All events giving rise to this action took place in Charleston County, South Carolina.
12. This Court has jurisdiction to hear the matter and venue is proper pursuant to S.C. Code §
15-7-30.
FACTUAL ALLEGATIONS
13. Plaintiff realleges and incorporates by reference the above numbered paragraphs as is set
forth herein verbatim.
14. Plaintiff, George Bolovis began employment with the City of Charleston in August 2019 and
graduated from the 19-02 recruit class as a certified level 2 fire fighter.
15. Plaintiff was hired to serve the Charleston community as a fire fighter and EMT.
16. Upon information and belief, the Fire Department’s values are: Honor, Commitment,
Community, Integrity, and Professionalism. See https://www.charleston-sc.gov/2012/
Mission-Vision-Values.
17. The City defines “Commitment” as “Duty and responsibility to our community and members
of the organization.”
Page 4 of 16
18. The City defines “Integrity” as “Being honest, respectful, and loyal to our community and
peers.”
19. The City defines “Professionalism” as “Achieve excellence through progressive training and
courteous service.”
20. Plaintiff espouses these same values and ideals. However, in Plaintiff’s personal experience
at the Fire Department and especially within Station 13, such values are not being upheld
and there is a complete lack of accountability for their disregard.
21. At the time of Plaintiff’s hire, Plaintiff entered the Fire Department as a probationary fire
fighter commonly referred to as a “grey shirt” because probationary fire fighters wear a grey
uniform shirt while fully vested fire fighters wear a blue uniform shirt.
22. During a fire fighter’s probationary period, the fire fighter is supposed to perform drills with
his or her unit and learn all of the ins and outs of the duties and responsibilities of a fire
fighter. During this probationary period, the fire fighter conducts physical exercises as well
as mental ones.
23. Plaintiff completed his probationary period and earned a blue shirt.
24. Plaintiff along several with other fire fighters from Engine 113, was awarded a Life Saving
Award on November 18, 2022 for exemplary service to the Charleston Community.
25. However, the City failed to notify Plaintiff about the award or ceremony thereby excluding
him from the awards ceremony. Plaintiff only later found out about the award through word
of mouth.
26. Even though only possessing the rank of fire fighter, Plaintiff volunteered for and was
appointed to the strategic planning committee for the City of Charleston Fire Department.
Page 5 of 16
27. Plaintiff is not a South Carolina native being originally from Queens, New York.
28. Plaintiff moved to Charleston from Alabama. In Alabama, Plaintiff was a member of the
Laborers Union, Local 366, employed through Day and Zimmermann, conducting job-site
safety inspections and supervisions to prevent fire hazards within Browns Ferry Nuclear
Power Plant.
29. Plaintiff is of Greek heritage and decent.
30. When Plaintiff joined the fire department, he was assigned to James Island, Station 13, in the
City of Charleston.
31. Upon information and belief, the individual fire fighters stationed on James Island are all, if
not mostly all, from James Island and the surrounding areas.
32. Upon information and belief, the individual fire fighters stationed on James Island for
Plaintiff’s same shift, at the time giving rise to this action, were tenured fire fighters with at
least 10 years of employment with the fire department and had been working together that
time.
33. Upon information and belief, these fire fighters viewed Plaintiff as an outsider and made sure
to treat him the same.
34. On one occasion while Plaintiff was still a grey shirt, Defendant Carter took Plaintiff on a
night drive by themselves and informed Plaintiff that Plaintiff did not belong at the James
Island fire station, would not be welcome there, and that Plaintiff would never fit in there
because he was an outsider.
35. On multiple occasions, Defendant Carter requested Plaintiff put in a request for a transfer out
of Defendant Carter’s Station on James Island.
Page 6 of 16
36. Even after Plaintiff completed his probationary period and was a full-blown blue shirt, the
fire fighters with whom Plaintiff was stationed continued to haze him and subject him to
drills, duties, and other tasks that they singularly imposed upon him alone.
37. One example of such hazing took place when Plaintiff was forced to drill, by himself, in full
fire fighter gear, including his mask with oxygen, for extensive periods of time. This drilling
served no purpose except to harass, intimidate, and abuse Plaintiff.
38. On the day of the incident giving rise to this action, Plaintiff was forced to do the above-
described drilling by himself and for no other reason but to harass, intimidate, and abuse
Plaintiff.
39. Another example of such hazing took place where Plaintiff was made to be the only person
to clean the bathrooms in the Station, as he was the lowest ranking and newest member of
the force.
40. Immediately after Plaintiff would finish cleaning the bathrooms, ranking personnel, and
specifically Defendant Carter, would relieve themselves/ himself by urinating on the floor of
the bathroom and then direct Plaintiff to go back in to finish cleaning the bathroom. This
happened on multiple occasions where ranking personnel would urinate on the floor
immediately after Plaintiff had finished cleaning and then instruct him to go back into the
bathroom to clean it again.
41. Another example of such hazing took place on another occasion when Plaintiff was eating
dinner. Plaintiff was eating with other staff when Defendant Carter interrupted the meal to
instruct Plaintiff to go clean the bathtub in the shower because Defendant Carter had “left
and oyster” in the shower. Defendant Carter used this euphemism to mean that he wanted
Page 7 of 16
Plaintiff to clean the showers where Defendant Carter had recently masturbated. While
Plaintiff refused to follow Defendant Carter’s order, Plaintiff understood Defendant Carter’s
intent to embarrass, intimidate, and harass Plaintiff.
42. As the newest member at the James Island station, Plaintiff was expected to singularly
perform all of the “grunt” work and labor-intensive upkeep tasks, like cleaning, yard-work,
and other similar tasks that would generally and ordinarily be shared among the while team
of fire fighters at the station.
43. On top of having to perform all of the station duties normally shared by the shift team,
Plaintiff was generally the only EMT for his shift which meant that Plaintiff had to respond
to all injury calls, handle all medical aspects, and complete all paperwork relating to all
injury calls. This singular responsibility fell to Plaintiff because the other fire fighters on his
shift were not required to be EMTs as is the current standard and requirement because they
were “grandfathered in.”
44. On another occasion, the fire fighters on the same shift as Plaintiff mocked his Greek
heritage when Plaintiff was asked to cook Greek food for everyone. Plaintiff made chicken
gyros and tzatziki sauce. After this meal, the other members of Plaintiff’s shift would mock
Plaintiff about the meal repeatedly telling him how disgusting they thought it was and so on.
45. Plaintiff continually endured such hazing and harassment because Plaintiff felt called to be a
fire fighter and wanted to serve the Charleston community.
46. Plaintiff hoped the hazing would stop if he endured it long enough. Unfortunately, that did
not happen and the hazing never stopped.
47. On October 15, 2020, the date of the incident giving rise to this action, Plaintiff was again
Page 8 of 16
singled out and made to perform drills by himself wearing full gear including oxygen mask
and other equipment.
48. After that hazing exercise ended, Plaintiff showered off and began his regular maintenance
and cleaning duties around the station to include making up his bunk.
49. On the date of the incident giving rise to this action, Plaintiff was making up his bunk when
he flipped over the bunk mattress to have it made up on Plaintiff’s preferred side of the
mattress because there is a firm side and soft side.
50. When Plaintiff flipped the mattress over and it landed back on the bed frame, some type of
incendiary device exploded from somewhere underneath his bunk.
51. Upon the explosion Plaintiff fell over onto the bed and then rolled onto the floor.
52. The explosion caused an extremely loud noise, which immediately made Plaintiff nauseated
and caused pain and ringing in his ears.
53. The explosion from the incendiary device created so much sulfuric smoke that the crew had
to open up the doors and windows of the fire station and turn on all of the fans to vent out the
smell and smoke from the station.
54. Right after the explosion, while Plaintiff was still on the ground, Defendant Carter came out
of his office in the adjacent room and asked Plaintiff what happened telling Plaintiff that he
thought that Plaintiff had brought a gun to work and shot himself in the head.
55. Defendant Carter’s comment demonstrates his actual knowledge of the hazing and its
severity such that Defendant Carter thought Plaintiff might have been so suicidal that he
brought a gun to work to kill himself there at the fire station.
56. Defendant Carter then walked back out of the bunk room without offering aid or saying
Page 9 of 16
anything else to Plaintiff and leaving Plaintiff lying on the floor.
57. When the explosion happened Plaintiff immediately reported to his supervisors and ranking
department employees the injury to his ears, ringing, and terrible headache that he was
experiencing.
58. Not one of Plaintiff’s supervisors or ranking personnel took any action in response to the
incident.
59. Plaintiff was not offered any medical assistance or evaluation.
60. No report was made by Plaintiff’s fellow employees or supervisors to the City of Charleston
or Fire Department leadership on the date of the incident about what happened or the harm to
Plaintiff.
61. After the explosion, Plaintiff finished out his shift in the computer room and on his bunk and
then went home.
62. After the incident, Plaintiff was pressured by his supervisors, including Defendant Carter and
Defendant Morris, to not report the incident or his injury to the City of Charleston or the
highest levels of the Fire Department.
63. Upon information and belief, Defendants Carter, Morris, and Haigler each took overt steps to
cover up the incident up to and including lying to ranking officials within the Fire
Department about the incident and his/their knowledge thereof.
64. Plaintiff ultimately had no choice but to seek medical attention because he had persistent
ringing in his ears, impaired hearing, hyperacusis, and ongoing headaches.
65. The explosion directly and proximately caused Plaintiff to suffer a permanent partial hearing
loss to the extent that Plaintiff can no longer qualify to work as a fire fighter ever again.
Page 10 of 16
AS A FIRST CAUSE OF ACTION
Battery
As to the Individually-Named Defendants
66. Plaintiff re-alleges and incorporates by reference all of the above paragraphs as if set forth
herein verbatim.
67. The use of an incendiary device by Defendants against Plaintiff as set forth above constitutes
the infliction of forcible contact on the person of another, namely Plaintiff.
68. The forcible contact with Plaintiff was the direct and proximate cause of serious physical
injuries to include damage to Plaintiff’s hearing, hyperacusis, and intractable headaches.
69. Upon information and belief, the above-named individual Defendants, acted in concert,
jointly and severally, to cause the battery described herein and resulting injuries to Plaintiff.
70. As set forth more fully in Plaintiff’s prayer for relief, the above-named individual
Defendants are liable, separately, individually, and/or jointly and severally for the
compensatory damages suffered by Plaintiff as a direct and proximate result of their actions
as set forth herein.
71. As set forth more fully in Plaintiff’s prayer for relief, the above-named individual
Defendants are liable, separately and individually, for punitive damages in this action.
AS A SECOND CAUSE OF ACTION

Civil Conspiracy
herein verbatim.
73. The above-named individual Defendants combined and conspired for the purpose of injuring
Plaintiff.
Page 11 of 16
74. These individual Defendants acted for the purpose of injuring Plaintiff by and through the
coordinated harassment, hazing, and abuse to cause such harm to Plaintiff to make him quit
his employment as a fire fighter, request transfer to another station, resign from the City of
Charleston, and/or commit suicide.
75. These Defendants committed such overt acts as forcing Plaintiff to drill alone in full gear,
singling Plaintiff out for hazing, pressuring other fire fighters in the station and department
to remain silent about the abuse suffered upon Plaintiff, lying about such abuse to hide the
truth from ranking officials with the Fire Department, and such other overt acts that might be
obtained through discovery and proved at trial.
76. Plaintiff suffered special damages as a direct and proximate result of the above-described
conspiracy. Those special damages include loss of employment, loss of ability to serve as a
fire fighter, emotional and mental distress, harm to reputation, and such other special
damages to be proved at the trial of this action.
AS A THIRD CAUSE OF ACTION

Violation of Fourteenth Amendment Pursuant to 42 U.S.C. § 1983
As to All Defendants
herein verbatim.
78. The Fourteenth Amendment of the United States Constitution guarantees certain recognized
substantive due process rights, including and specifically the rights to life, liberty, and bodily
integrity. These rights have been incorporated through the 14th Amendment as to the States
and such political subdivisions as the City of Charleston. See e.g., Ingraham v. Wright, 430
U.S. 651 (1977) (recognizing right to bodily integrity as a liberty interest under the 14th
Page 12 of 16
Amendment).
79. The City of Charleston is a municipality subject to suit pursuant to 42 U.S.C. § 1983 as the
City is a “person” as defined by the Supreme Court of the United States. Monell v. Dept. of
Social Services, 436 U.Sd. 658 (1978).
80. The individually-named Defendants, at all times relevant herein, were employees of the City
of Charleston Fire Department and interacted with Plaintiff in such capacity as an employee
of the City of Charleston.
81. The individually-named Defendants, during all relevant times herein, were state actors and
acting under the color of state law.
82. The City of Charleston, by and through the ranking supervisors, Defendant Morris,
Defendant Carter, and/or Defendant Haigler, deliberately established and/or adopted policies,
procedures, customs, and practices that Defendants knew violated Plaintiff’s substantive due
process rights. Furthermore, Plaintiff understands and believes that Defendants intentionally
adopted the practice, custom, policy, and procedure of hazing, harassment, intimidation, and
abuse with the intent of harming Plaintiff including causing physical injury in addition to
taking Plaintiff’s ability to work and serve his community as a fire fighter.
83. Defendants’ conduct as set forth herein above was deliberately intended to injure Plaintiff,
shocks the conscience, and constitutes an arbitrary executive abuse of power. In addition
and/or in the alternative, Defendants were deliberately indifferent to the substantive due
process rights of Plaintiff by subjecting him to hazing and harassment culminating in the use
of an explosive device intended to injure and harm Plaintiff.
84. In addition, the use of the explosive device by a person acting under the color of state law is
Page 13 of 16
an intentional, conscience shocking, and deliberate assault on Plaintiff’s substantive due
process right to bodily integrity by the individually-named Defendants as set forth above.
85. As a direct and proximate result of the deliberate indifference and/or intentional acts by
Defendants, as state actors and/or individuals acting under color of state law, Plaintiff
suffered serious and permanent bodily injury in addition to other compensatory damages.
The individually-named Defendants are each liable for the punitive damages arising out of
their own specific and individual acts of intentional harm and deliberate indifference.
AS A FOURTH CAUSE OF ACTION

Intentional Infliction of Emotional Distress/ Outrage
herein verbatim.
87. Defendants intentionally and/or recklessly inflicted severe emotional distress through the
above-described acts and/or omissions.
88. In addition and/or in the alternative, it was certain or substantially certain that such distress
would result from Defendants’ conduct described more fully above.
89. Defendants’ conduct was so extreme and outrageous as to exceed all possible bounds of
decency and must be regarded as atrocious and utterly intolerable in a civilized community.
90. Such outrageous conduct included intentionally urinating on the floor of the bathroom so that
Plaintiff would have to clean up the urine, masturbating in the facility so that Plaintiff would
have to clean up Defendant’s bodily fluids, forcing Plaintiff to perform drills in full gear
alone and with the sole purpose of harassing, intimidating, hazing, and embarrassing
Plaintiff.
Page 14 of 16
91. No decent society should or would tolerate such conduct and the Charleston community
should not tolerate such conduct - especially within public service departments who are
employed to protect the health and safety of the community and its residents.
92. Defendants actions were the direct and proximate cause of severe emotional distress upon
Plaintiff and such distress was so severe that no reasonable man could be expected to endure
it.
93. Defendants are liable, individually and jointly and severally, for the compensatory damages
caused by their extreme and outrageous conduct, and the punitive damages that may be
awarded by the finder of fact against the individually-named Defendants separately and
independently for each Defendant’s own conduct.
PRAYER FOR RELIEF
94. Wherefore, Plaintiff prays for the following:
A. Judgment against Defendants, individually and/or jointly and severally, for all
compensatory damages found and awarded by the trier of fact in this action;
B. Judgment against Defendants, individually and/or jointly and severally, for all special
damages found and awarded by the trier of fact in this action;
C. Judgement against the individually-named Defendants, individually and separately, for
punitive damages found and awarded by the trier of fact in this action;
D. An award of reasonable attorneys fees and costs pursuant to 42 U.S.C. § 1988;
E. And any and all such other relief that the Court and/or the trier of fact find to be just and
proper.
Page 15 of 16
Respectfully Submitted,
APOSTOLOU LAW FIRM
/S/ Michael Thomas Cooper

Michael Thomas Cooper, SC Bar 100053
3443 Rivers Avenue
North Charleston, SC 29405
Ph (843) 853-3637
[email protected]
Attorney for Plaintiff
Dated: Thursday, October 12, 2023

North Charleston, South Carolina
Page 16 of 16

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ELECTRONICALLY FILED - 2023 Oct 12 12:39 PM - CHARLESTON - COMMON PLEAS - CASE#2023CP1005032

STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS

TO THE ABOVE-NAMED DEFENDANTS:

APOSTOLOU LAW FIRM

/S/ Michael Thomas Cooper

the Court as follows:

change this litigation might bring about.

PARTIES AND JURISDICTION

5. Plaintiff, George Bolovis (hereinafter referred to as “Plaintiff” or “Bolovis”), is a citizen and

operates the Charleston Fire Department (hereinafter “CFD” or “Fire Department”), a

department within the municipal subdivision.

was an employee of the City of Charleston and the Fire Department.

was an employee of the City of Charleston and the Fire Department.

was an employee of the City of Charleston and the Fire Department.

forth herein verbatim.

Community, Integrity, and Professionalism. See https://www.charleston-sc.gov/2012/

and there is a complete lack of accountability for their disregard.

29. Plaintiff is of Greek heritage and decent.

to treat him the same.

because he was an outsider.

of Defendant Carter’s Station on James Island.

served no purpose except to harass, intimidate, and abuse Plaintiff.

bathroom to clean it again.

intent to embarrass, intimidate, and harass Plaintiff.

of fire fighters at the station.

were “grandfathered in.”

fire fighter and wanted to serve the Charleston community.

not happen and the hazing never stopped.

and other equipment.

mattress because there is a firm side and soft side.

incendiary device exploded from somewhere underneath his bunk.

and caused pain and ringing in his ears.

smell and smoke from the station.

brought a gun to work to kill himself there at the fire station.

59. Plaintiff was not offered any medical assistance or evaluation.

then went home.

highest levels of the Fire Department.

Department about the incident and his/their knowledge thereof.

ringing in his ears, impaired hearing, hyperacusis, and ongoing headaches.

the infliction of forcible contact on the person of another, namely Plaintiff.

injuries to include damage to Plaintiff’s hearing, hyperacusis, and intractable headaches.

as set forth herein.

AS A SECOND CAUSE OF ACTION

Charleston, and/or commit suicide.

obtained through discovery and proved at trial.

damages to be proved at the trial of this action.

AS A THIRD CAUSE OF ACTION

Social Services, 436 U.Sd. 658 (1978).

of the City of Charleston.

acting under the color of state law.

of an explosive device intended to injure and harm Plaintiff.

AS A FOURTH CAUSE OF ACTION

above-described acts and/or omissions.

would result from Defendants’ conduct described more fully above.

independently for each Defendant’s own conduct.

PRAYER FOR RELIEF