From the Complaint in Arnold v. Concordia Int'l Univ., filed Monday:
15. WAYNE is informed and believes that sometime between 11:00 pm and midnight on February 12, 2022, KNUCKLES and/or SANDERS noticed that a PlayStation 5 ("PS5") was missing from their room.
16. WAYNE is informed and believes that based on racial animus, racial discrimination, racial profiling and racial bias, KNUCKLES concluded that "it must have been WAYNE" who stole the PS5.
17. WAYNE shares a dorm room with his roommate and KNUCKLES and SANDERS share a room adjacent to WAYNE's room….
19. WAYNE is informed and believes that KNUCKLES provided a statement to school authorities that "WAYNE was the last person he'd seen leaving the SUITE of ROOMS before he noticed the PS5 was missing."
20. WAYNE is informed and believes that no other evidence exists connecting him to the claim that he stole the PS5.
21. A few days later, on or about February 17, 2022, WAYNE was expelled from the basketball team where he was a star player after a brief "Star Chamber" type interview WAYNE had with AMMANN and the basketball coaching staff.
22. WAYNE received no proper notice of the charges against him by the basketball coaching staff and received no fair process in violation of his due process rights.
23. In addition, WAYNE was asked about a number of other completely uncorroborated allegations of theft from other students and/or other members of the basketball team.
24. WAYNE had no notice of these other allegations.
25. WAYNE never had a chance to review the details of the statements made against him and was not permitted to proffer evidence or statements to prove his innocence of the charge that he stole the PS5.
26. WAYNE is informed and believes that the other uncorroborated allegations against WAYNE were, like the allegations of KNUCKLES and SANDERS, the product of conjecture and/or speculation based on racial animus, racial discrimination, racial profiling and racial bias.
27. In short, WAYNE was expelled from the basketball team without any due process based on a complete lack of credible evidence, where the charges or allegations were the product of conjecture and/or speculation and based on racial animus, racial discrimination, racial profiling and racial bias.
Arnold claims race discrimination, violation of due process, defamation, infliction of emotional distress, negligence, and breach of contract.
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