7/30/2019 Packer Complaint

1/2

1

ASHLEY MORGAN

IN THE UNITED STATES DISTRICT COURTFOR THE WESTERN DISTRICT OF MISSOURI

WESTERN DIVISION

[CAPTION]

COMPLAINT

Parties

1. Plaintiff, Patrick Packer (Packer), is a citizen of the state of Missouri and a resident

of Kansas City, Jackson County, Missouri, in the Western District of Missouri.

2. Defendant, Dennis Denton (Denton), is a citizen of the state of Kansas and a resident

of Fairway, Johnson County, Kansas.

Jurisdiction and Venue

3. This is an action brought under 42 U.S.C 1982.

4. This Court has jurisdiction over this action under 28 U.S.C. 1343 (4), and 28 U.S.C.

1331.

5. Venue is properly placed in this Court under 28 U.S.C. 1391 (b)(2) since a substantial

part of the events or omissions giving rise to the claim took place in this District.

COUNT I

Facts

6. Plaintiff incorporates by reference each and every allegation contained in paragraphs 1

through 5 above.

7. On or about July 14, 2006, Packer learned of Dentons house for sale from a classified

advertisement in the Kansas City Star.

8. Denton followed Packer as he was trying to visually inspect house as if Packer wasgoing to steal from the house.

9. Denton intentionally tried to dissuade Packer from buying house by exaggerating

numerous deficiencies while excluding all positive features of house, such as detailing a

tiny water spot on bedroom ceiling, instead of noting the rooms great closet space and

beauty.

7/30/2019 Packer Complaint

2/2

2

10. Denton refused to negotiate the sale price of house even after Packer offered to pay

cash for the reasonable amount of $250,000 with no contingencies.

11.Denton became annoyed with Packer and stated that Packers offer will not even be

considered due to race.

12. Denton has sold the house as of February 12, 2007 to another couple.

13. Denton violated 42 U.S.C. 1982 by allowing race to be a motivating factor in:

a. discouraging Packer from viewing house,

b. discouraging Packer from making an offer on house,

c. refusing to sell house to Packer, and

d. refusing to negotiate sale price of house

14. Dentons racially discriminatory conduct was willful, wanton and malicious entitling

Packer to punitive damages in the amount of $100,000

Prayer

WHEREFORE, Plaintiff Packer prays for judgment against Defendant Denton on Count I

of plaintiff's complaint as follows:

A. Judgment against Defendant Dennis Denton in the amount of $10,000 compensatory

damages for Plaintiff Patrick Parkers emotional distress and humiliation after being

discouraged and rejected from buying Defendants house solely because of Parkers race.

B. Judgment against Defendant Dennis Denton in the amount of $100,000 punitive and

exemplary damages for his willful, wanton and malicious racial discrimination against

Plaintiff Patrick Packer.

C. Judgment against Defendant Dennis Denton for the cost of gas and time spent viewing

the home.

D. Judgment for such other relief as is just.

DEMAND FOR JURY TRIAL

Plaintiff demands trial by jury on all issues.

[SIGNATURE BLOCK]