# AMOUZOU

> District Court, E.D. Pennsylvania · October 21, 2025

URL: https://www.frixlaw.com/law-library/cases/11174946

## Case

- **Full name:** Komla Amouzou v. County of Delaware, et al.
- **Court:** District Court, E.D. Pennsylvania
- **Decided:** October 21, 2025
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/11174946

## Opinion text

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA

KOMLA AMOUZOU :
: CIVIL ACTION
:
Plaintiff, :
v. :
:
COUNTY OF DELAWARE, et al. : NO. 23-2988
:
Defendants. :

J. Perez October 21, 2025
MEMORANDUM
Plaintiff Komla Amouzou brings this employment action against the County of Delaware,
Delaware County Jail Oversight Board (“the Board”), Warden Laura Williams, and the Board
Chairman Kevin Madden, arising from the County’s decision not to hire him when it assumed
control of the George W. Hill Correctional Facility from its former private operator. Plaintiff asserts
claims for race discrimination under the Equal Protection Clause (Count I) and violations of
procedural due process (Count II).
Defendants move for summary judgment on all claims. Plaintiff concedes summary
judgment on Count II, so the Court does not address that claim. Plaintiff also concedes that
Delaware County cannot be held liable under Monell v. Department of Social Services, 436 U.S.
658 (1978). For the reasons set forth below, the Court concludes that Plaintiff has not produced
evidence from which a reasonable jury could find intentional discrimination by any Defendant.
Defendants’ motion for summary judgment will therefore be granted.
I. Factual Background
Plaintiff Komla Amouzou worked as a correctional officer and, beginning in 2019, as a
correctional sergeant at the George W. Hill Correctional Facility (“the Facility”) in Delaware
County.1 At that time, the Facility was operated by The GEO Group, Inc. (“GEO”), a private
contractor.2 On September 28, 2021, the Delaware County Jail Oversight Board voted to terminate
the County’s contract with GEO, and on October 6, 2021, the Delaware County Council voted to

end GEO’s private management of the Facility.3 The County assumed control of the Facility on
April 6, 2022.4
In preparation for this transition, the County appointed Laura Williams as Warden and
contracted with Juno, a third-party recruitment firm, to assist in screening applicants.5 GEO
employees were advised that employment with the County was not guaranteed, and those
interested in continuing to work at the Facility were required to submit applications and undergo

interviews and background checks. Warden Williams personally interviewed thirty-four GEO
employees who applied for correctional sergeant positions and eight GEO employees who applied
for correctional lieutenant positions.6
Amouzou applied for a correctional sergeant position with the County and was interviewed
by Warden Williams on March 10, 2022.7 Williams recommended him for hire, and the County
extended a conditional offer of employment around March 15, 2022.8 The offer stated that

1 ECF 27-7 at 12:21–13:11.
2 See ECF 27-3.
3 See ECF 27-4.
4 ECF 27-6 at 19:25–20:14.
5 ECF 27-5 at ¶¶2-7.
6 ECF 27-9.
7 Id. at 6:24–7:13.
8 ECF 27-7.
employment was contingent upon the successful completion of a background check and other
requirements, and identified April 6, 2022, as the target start date.9

As part of the background check, the County reviewed records provided by GEO. During
this process, Warden Williams received an investigative report prepared by GEO Investigator
Keith Heyward regarding a substantiated use-of-force violation involving Amouzou in May
2020.10 After reviewing the report, Warden Williams concluded that the conduct was inconsistent
with the County’s mission to elevate standards and uphold constitutional protections of
incarcerated individuals.11 Warden Williams decided to rescind Amouzou’s conditional offer, and
Amouzou received verbal and written notice of that decision on April 4, 2022.12 His counsel
requested reconsideration, but the County reaffirmed its decision on April 20, 2022, citing the GEO
findings.13

Warden Williams testified that she applied uniform, neutral hiring criteria to all candidates
and excluded those with significant disciplinary histories or egregious policy violations, including
substantiated use-of-force incidents. She did not receive any comparable disqualifying information
concerning other sergeant or lieutenant candidates who were hired.14 Amouzou acknowledged that
he had no personal knowledge of any other candidate hired by the County who had a substantiated
use-of-force violation.15

Plaintiff asserts that two white sergeants, Sergeants Serody and McCafferty, were hired by
the County despite having previously been involved in use-of-force incidents while employed by

9 ECF 27-11.
10 ECF 27-13; ECF 27-6 at 21:18–22:2; ECF 27-7 at 27:6–16; ECF 27-19 at 33:1–39:14.
11 ECF 27-6 at 7:14–8:20.
12 Id.; ECF 27-14.
13 ECF 27-16; ECF 27-7 at 39:2–41:7.
14 ECF 27-6 at 8:6–15, 10:1-11:12, 26:2–19.
15 ECF 27-7 at 48:4–7, 49:8–11.
GEO. The only evidence Plaintiff offers to support this assertion is his own deposition testimony,
which does not reflect that he had personal knowledge of either individual’s disciplinary history.16
Plaintiff points to Serody’s employment interview form, which indicates no policy violations, and
to Warden Williams’s deposition testimony, in which she stated she was not aware of any
disciplinary history concerning McCafferty.17 Plaintiff has produced no disciplinary records,

personnel files, or other documentary evidence to substantiate his claims regarding these
comparators.
The County’s hiring data further reflects the absence of discriminatory treatment. During
the transition, the County hired thirty-two sergeants: twenty-one identified as Black (65.63%) and
eleven as White (34.38%). The County also hired seven lieutenants: four identified as Black
(57.14%), two as White (28.57%), and one as Hispanic (14%).18 Two sergeant candidates—one

Black and one White—were offered positions as correctional officers due to insufficient
supervisory experience.19
II. Equal Protection Claim Against Individual Defendants
Plaintiff asserts that Warden Laura Williams and other individual County officials
intentionally discriminated against him on the basis of race in violation of the Equal Protection
Clause of the Fourteenth Amendment. Claims for intentional race discrimination under § 1983 are
analyzed under the same framework applicable to Title VII disparate treatment claims. See St.
Mary's Honor Ctr. v. Hicks, 509 U.S. 502 (1993). Under the applicable burden-shifting framework

established by McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802 (1973), Plaintiff must first

16 Id.
17 ECF 27-6 at 10:17-11:10.
18 ECF 27-17.
19 ECF 27-6 at 24:4–25:19, 27:7–28:8.
establish a prima facie case by demonstrating that (1) he is a member of a protected class; (2) he
was qualified for the position; (3) he suffered an adverse employment action; and (4) similarly
situated individuals outside his protected class were treated more favorably. Jones v. School Dist.
of Philadelphia, 198 F.3d 403, 410–11 (3d Cir. 1999). If Plaintiff establishes a prima facie case,

the burden shifts to Defendants to articulate a legitimate, nondiscriminatory reason for their
decision. Id. The burden then shifts back to Plaintiff to present evidence from which a reasonable
jury could find that the stated reason was pretextual. Fuentes v. Perskie, 32 F.3d 759, 763 (3d Cir.
1994).
Here, Plaintiff satisfies the first three elements of the prima facie case. However, he fails
to produce evidence sufficient to show that similarly situated individuals outside his protected
class were treated more favorably. Plaintiff identifies two white sergeants—Serody and

McCafferty—who he alleges were hired despite having histories of use-of-force violations similar
to his own. However, the only evidence Plaintiff offers to support this allegation is his own
deposition testimony, which does not reflect that he had personal knowledge of either individual’s
disciplinary history. Plaintiff cites Serody’s employment interview form, which indicates that he
denied any policy violations, and Warden Williams’s testimony that she was not aware of any
disciplinary history regarding McCafferty. Plaintiff offers no disciplinary records, personnel files,
or other competent evidence substantiating his assertions. Unsupported allegations and speculation
are insufficient to defeat summary judgment. See Jones v. United Parcel Serv., 214 F.3d 402, 407
(3d Cir. 2000). Plaintiff was not involved in the County’s hiring decisions, did not review personnel

files, and does not claim to have witnessed the alleged incidents. See id.; Blair v. Scott Specialty
Gases, 283 F.3d 595, 608 (3d Cir. 2002).
Furthermore, to qualify as comparators, individuals must be similarly situated in all
relevant respects, meaning they “dealt with the same supervisor, were subject to the same
standards, and had engaged in similar conduct without such differentiating or mitigating
circumstances as would distinguish their conduct or the employer’s treatment of them.” Opsatnik

v. Norfolk S. Corp., 335 F. App’x 220, 223 (3d Cir. 2009) (citation omitted). Plaintiff has made no
showing that Serody and McCafferty were similarly situated in this sense. He has not demonstrated
that their disciplinary histories were comparable in seriousness, that the County was aware of any
such histories, or that they were evaluated under the same criteria. Because Plaintiff’s comparator
evidence consists of unsubstantiated allegations and speculation, it is insufficient to create a
genuine dispute of material fact. See Jones, 214 F.3d at 407; Blair, 283 F.3d at 608. Absent
evidence of valid comparators, no reasonable jury could infer that the decision to rescind Plaintiff’s
offer was motivated by race rather than by the substantiated use-of-force violation. Plaintiff
therefore fails to satisfy the fourth element of his prima facie case and cannot establish
discriminatory intent on this record.

Even assuming Plaintiff could establish a prima facie case, Defendants have articulated a
legitimate, nondiscriminatory reason for rescinding Plaintiff’s offer: a substantiated GEO
investigative report finding that Plaintiff violated use-of-force policies. Plaintiff has not produced
evidence from which a reasonable jury could find this explanation pretextual. He offers no
evidence suggesting that Warden Williams or any other defendant disbelieved the GEO report,
applied the hiring criteria inconsistently, or acted with discriminatory animus. The record shows

that Warden Williams applied uniform hiring standards to all applicants, excluding candidates with
significant disciplinary histories, and that Plaintiff’s offer was rescinded pursuant to those
standards. Plaintiff’s disagreement with the County’s reliance on GEO’s findings does not establish
pretext. See Fuentes, 32 F.3d at 765.

III. Conclusion
Because Plaintiff has failed to raise a genuine dispute of material fact as to whether the
individual defendants intentionally discriminated against him on the basis of race, summary
judgment will be entered in favor of Warden Williams and Madden on Count I. Plaintiff concedes
all remaining claims. Accordingly, Defendants’ motion for summary judgment will be granted in
its entirety.

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11174946. Public record. Not legal advice.