Civil Rights and FLSA Complaint – LeRette v. City of Superior & Champaigne (March 7, 2025)

This federal complaint, filed on March 7, 2025, details a civil rights and employment law action brought by Mikayla Marie LeRette against the City of Superior, Wisconsin, and former Police Captain Thomas Champaigne. The document outlines two primary legal claims: a Fourth Amendment violation under 42 U.S.C. § 1983 involving the warrantless placement of an electronic tracking device on her assigned police vehicle, and a Fair Labor Standards Act (FLSA) violation under 29 U.S.C. § 218d concerning the City’s failure to provide a legally compliant lactation space following the birth of her first child.

The complaint recounts that LeRette became pregnant in 2021 and returned from maternity leave in late 2022. Upon her return, she requested reasonable break time and an appropriate lactation area, as required by federal law. Despite notifying her supervisors, including Lieutenant Michelle Pope and the Chief of Police, no adequate private space was provided. Instead, she was forced to lactate in a women’s locker room and behind a shower curtain with little privacy. Throughout the following months, she experienced repeated intrusions by male staff and other personnel, including deliberate interruptions and conduct perceived as dismissive or hostile.

In addition to the FLSA issues, the complaint alleges that in February 2024, Captain Champaigne secretly placed a GPS tracking device on LeRette’s assigned police vehicle without a warrant. After her vehicle went in for repairs, he allegedly removed the device and reinstalled it on her temporary replacement vehicle. Although he claimed the device was removed shortly before his retirement, an internal investigation indicated that tracking continued into late March 2024. LeRette asserts she never consented to the use of such a device, making the warrantless surveillance unlawful under established Fourth Amendment precedent.

The complaint seeks compensatory and punitive damages, attorney’s fees, and any other relief the court finds appropriate. It argues that the City of Superior is vicariously liable for Champaigne’s actions under Wisconsin statute § 895.46, even though no policy-based claim is alleged. The filing concludes with verification that all required conditions precedent have been satisfied.

File Type: pdf
File Size: 130 KB
Tags: City of Superior Wisconsin, Fair Labor Standards Act, federal civil rights lawsuit, Fourth Amendment, GPS vehicle tracking, Michelle Pope, Mikayla Marie LeRette, police department misconduct, Thomas Champaigne, workplace lactation rights