Date: 07-03-2025

Case Style:

Kurt Alexander v. Sterlin Proctor, et al.

Case Number: 24-CV-2752

Judge: Paul Xinis

Court: United States District Court for the District of Maryland (Baltimore County)

Plaintiff's Attorney: Stephen Fowler

Defendant's Attorney: Untied States District Attorney's Office in Balimore

Description: Baltimore, Maryland personal injury lawyer represented the Plaintiff on a 42 U.S.C. 1983 civil rights violation claim.

In the spring of 2021, Plaintiff Kurt Alexander (“Alexander”) worked as a law enforcement officer for Federal Protective Services (“FPS”), an arm of the Department of Homeland Security (“DHS”), and lived in private military housing at Joint Base Andrews in Maryland (the “Base”). On April 28, 2021, while off-duty, Alexander contacted the Base police to inform them that two weeks prior, a person with “mental health issues” who did not live on the Base had illegally snuck guns onto the premises. Alexander refused to share the person's identity with the Base police, which “caused friction,” with the officers.

While Base police continued to talk with Alexander over the phone, they grew concerned about his “statements and demeanor.” So, they told Alexander they were headed to his home. Alexander objected, noting he had just taken “his night meds,” which made him drowsy. This vague reference to medication, in combination with Alexander's behavior, prompted the officers to ask Alexander whether he had taken “anti-psychotic[s],” which he denied. Alexander also continued to resist meeting with law enforcement, telling officers that he would only consider meeting “somewhere away from [his] house.”

At some point, the Base police grew concerned that Alexander had “barricaded” himself in the home with his young children. The officers, in turn, enlisted the help of Alexander's supervisor, Defendant Sterling Proctor, as well as agents from the Federal Bureau of Investigation and a hostage negotiator to help coax Alexander out of the house. Eventually, Proctor convinced Alexander to meet in front of his home.

As Alexander emerged from the home, law enforcement officers “surrounded” him. Alexander agreed that officers could search the home and check on his children, although later he claimed such consent was coerced. Id. Officers ultimately found and seized firearms from the residence.

As the April 28 events unfolded, Proctor contacted Alexander's wife to ask what medications Alexander had been taking, ECF No. 42-6 at 7. She replied that Alexander only takes cholesterol medication.

The next day, FPS opened an investigation, placed Alexander on administrative leave, and required that he turn in his gun and badge. He returned to work pending an internal investigation that lasted nine-months, during which time he was relegated to desk duties. Alexander, in response, took legal action.

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Legal issue Can an employer's inquiry into an employee's medication use, during a situation involving safety concerns, constitute disability discrimination or create a hostile work environment under the Rehabilitation Act?
Headnote

DISABILITY DISCRIMINATION LAW. DISCRIMINATORY INQUIRY. The case involves a claim of disability discrimination under the Rehabilitation Act based on an employer's inquiry into the plaintiff’s medication, where the court had to determine if the inquiry was job-related and consistent with business necessity.

EMPLOYMENT LAW. HOSTILE WORK ENVIRONMENT. The court addresses whether a single incident of inquiry about medication could constitute a hostile work environment under the Rehabilitation Act, ultimately concluding that the interaction was not severe or pervasive enough to alter the terms and conditions of employment.

Key Phrases Disability discrimination. Hostile work environment. Summary judgment. Rehabilitation Act claims. Federal Protective Services investigation.

Outcome: Motion for summary granted.

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Defendant's Experts:

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