Joseph Simmons v. Ken Decker, Lauren Gutierrez, Trudena Horsey, Donna Barnes, Kent County Levy Court, Taylor Buckett, and Kevin Sipple, in his official capacity only

CourtDistrict Court, D. Delaware
DecidedFebruary 5, 2026
Docket1:25-cv-00113
StatusUnknown

This text of Joseph Simmons v. Ken Decker, Lauren Gutierrez, Trudena Horsey, Donna Barnes, Kent County Levy Court, Taylor Buckett, and Kevin Sipple, in his official capacity only (Joseph Simmons v. Ken Decker, Lauren Gutierrez, Trudena Horsey, Donna Barnes, Kent County Levy Court, Taylor Buckett, and Kevin Sipple, in his official capacity only) is published on Counsel Stack Legal Research, covering District Court, D. Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Joseph Simmons v. Ken Decker, Lauren Gutierrez, Trudena Horsey, Donna Barnes, Kent County Levy Court, Taylor Buckett, and Kevin Sipple, in his official capacity only, (D. Del. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE JOSEPH SIMMONS, ) ) Plaintiff, ) ) v. ) ) C.A. No. 25-113-JLH-LDH KEN DECKER, LAUREN GUTIERREZ, ) TRUDENA HORSEY, DONNA BARNES, ) KENT COUNTY LEVY COURT, a municipal ) FILED corporation in Delaware, TAYLOR BUCKETT, _ ) and KEVIN SIPPLE, in his official capacity only, — ) ) FEB -5 2026 Defendants. ) REPORT AND RECOMMENDATION? 2IO° COURT PstI OF □□ □□ Pending before the Court is Defendants Ken Decker (“Decker”), Lauren Gutierrez (“Gutierrez”), Trudena Horsey (“Horsey”), Donna Barnes (“Barnes”), Kent County Levy Corut (“Kent County”), Taylor Buckett (“Buckett”), and Kevin Sipple’s (“Sipple”) (collectively, “Defendants”) Motion to Dismiss Plaintiff Joseph Simmons’ (“Plaintiff”) Amended Complaint. (D.I. 27 (the “AC”)). The motion has been fully briefed. (D.I. 29, 31,32). For the following reasons, | recommend that Defendants’ Motion to Dismiss be GRANTED-IN-PART and DENIED-IN-PART. I. BACKGROUND This action arises out of Defendants alleged wrongful termination of Plaintiff in violation of his First and Fourteenth Amendment rights and Title VII of the Civil Rights Act of 1964. (See generally AC). Plaintiff began working in 2014 for Kent County as an Information Technology consultant and was promoted to Director of Information Technology in 2022. (Id. 4 17-20). Plaintiff was an Employee Council member that was duly elected according to the Employee Council By-Laws. Ud. § 1). In May of 2014, Plaintiff spoke at an Employee Council Meeting.

(Id. at 21). According to Plaintiff, the Member of the Employee Council were “anticipating that they would provide to Defendant Kent County” proposed recommendations regarding vacation days and military services policies. (dd. 22). The President of the Employee Counsel drafted a letter that allegedly did not accurately represent the recommendations of the Employee Council with respect to those policies but, following the objection of the Employee Council Members, he did not deliver it to Kent County. (/d. 423). So, on May 15, 2024, Plaintiff spoke at the Employee Council Meeting about the contents of the letter that was drafted but never sent. (id. | 24). At the Meeting, Plaintiff urged the Employee Council to vote regarding the recommendations contained in the unsent letter. (/d.). The following week, Gutierrez and Horsey demanded that Plaintiff resign from Employee Council. (Ud. § 27-28). Plaintiff refused and was then given a written warning for “unprofessionally flicking his pen” in Gutierrez’s direction. (id. J] 27-30). In July, less than two months after Plaintiff spoke at the Employee Council Meeting, Gutierrez and Horsey placed Plaintiff on a Performance Improvement Plan (“PIP”). (/d. 131). Plaintiff “successfully disputed” certain portions of the PIP and he was told that changes would be made, but he was never provided with a revised PIP. (Jd. 31-33). The PIP that was presented to Plaintiff was for a 6-month period. (fd. | 32). Several weeks after being put on the PIP, Plaintiff was notified that he would be placed on administrative leave pending an investigation into his allegedly false statements regarding outsourcing in the IT department. (/d. [§ 34-35). Plaintiff maintains that any such statements were not improper. (/d. | 26 —37). Plaintiff was then provided with a memo written by Horsey which recommended termination and, despite his appeal to Gutierrez, Plaintiff was terminated on September 10, 2024. Ud. 9] 39-40, 45-47).

II. LEGAL STANDARD a. Motion to Dismiss In reviewing a motion filed under Rule 12(b)(6), the Court must “accept all factual allegations as true [and] construe the complaint in the light most favorable to the plaintiff.” Phillips v. Cnty. of Allegheny, 515 F.3d 224, 233 (3d Cir. 2008) (internal quotation marks omitted). A Rule 12(b)(6) motion may be granted only if, accepting the well-pleaded allegations in the complaint as true and viewing them in the light most favorable to the plaintiff, a court concludes that those allegations “could not raise a claim of entitlement to relief.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 558 (2007). The complaint need not contain detailed factual allegations, but conclusory allegations and “formulaic recitation[s] of the elements of a cause of action” are insufficient to give the defendant fair notice of the nature of and grounds for the claim. Twombly, 550 U.S. at 555. The complaint must contain facts sufficient to show that a claim has “substantive plausibility.” Johnson v. City of Shelby, 574 U.S. 10, 12 (2014) (per curiam). While this plausibility standard requires more of the complaint than allegations supporting the mere possibility that the defendant is liable as alleged, plausibility should not be taken to mean probability. Twombly, 550 U.S. at 545. A claim is facially plausible, and the standard is satisfied, when the claim’s factual allegations, accepted as true, allow the court to reasonably infer that the defendant is liable as alleged. Ashcroft v. Iqbal, 556 U.S. 662, 1948 (2009). III. DISCUSSION a. Free Speech and Freedom of Association Claims (Counts I & IV) Plaintiff alleges that he engaged in Constitutionally protected speech and that Defendants violated his right to free speech by retaliating against him. (AC 23-25, 92). To plead a claim

for First Amendment retaliation under 42 U.S.C. § 1983, a Plaintiff must allege: (1) he engaged in constitutionally protected speech; (2) defendant took retaliatory action sufficient to deter a person from exercising his constitutional rights; and (3) there is a causal link between the conduct and the adverse action taken against him. Palardy v. Twp. of Millburn, 906 F.3d 76, 80-81 (3d Cir. 2018); Garcetti v. Ceballos, 547 U.S. 410, 418 (2006). In determining whether an employee’s speech addresses a matter of public concern, the court must look at the “‘content, form, and context of a given statement, as revealed by the whole record.’” Rankin v. McPherson, 483 U.S. 378, 384-85 (1987) (quoting Connick v. Myers, 461 U.S. 138, 147-48 (1983)). Defendants argue that Plaintiff does not allege that he engaged in protected speech, that he fails to allege retaliatory conduct, and that he fails to plead a causal link between the protected activity and the adverse action. (D.I. 29 at 6-9). Failure to adequately plead any of the three requirements compels me to dismiss this cause of action. To determine whether a public employee’s speech is protected, courts apply a three-part test: (1) whether the employee spoke as a private citizen, rather than an employee; (2) whether, when speaking as a private citizen, the speech involved a matter of public concern; and (3) whether the government entity had an adequate justification for treating the employee differently from any other member of the general public. Garcetti v. Ceballos, 547 U.S. 410, 418 (2006).' As an initial matter, | was unable to locate any averments in the AC supporting the inference that Plaintiff was speaking at the Employee Council meeting as a private citizen, and not as an employee. That said, even if | assumed that Plaintiff's averments were sufficient in this regard, | do not agree that Plaintiff was speaking on a matter of public concern. Plaintiff argues

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Bluebook (online)
Joseph Simmons v. Ken Decker, Lauren Gutierrez, Trudena Horsey, Donna Barnes, Kent County Levy Court, Taylor Buckett, and Kevin Sipple, in his official capacity only, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joseph-simmons-v-ken-decker-lauren-gutierrez-trudena-horsey-donna-ded-2026.