The police chief at the University of Maryland, Baltimore County, is seeking dismissal of a claim against him in a class-action lawsuit that alleges Baltimore County law enforcement and prosecutors fostered a culture to dismiss and cover up complaints of sexual assault.

According to the civil lawsuit, two women say they were sexually assaulted by UMBC students in separate incidents. The case alleges that authorities then humiliated, intimidated and deceived them as part of an intentional effort to “cover up justifiable complaints of sexual assault.”


The lawsuit alleges that Paul Dillon, then deputy chief of police at UMBC, “improperly persuaded” a UMBC student to not report her alleged assault to police. It also contends that UMBC failed to record the assault in federal reporting statistics or forward the assault to the Baltimore County Police Department, as required in a memorandum of understanding between the two institutions.

In a memorandum in support of Dillon’s motion to dismiss, Maryland Attorney General Brian Frosh stated that Dillon never tried to dissuade the plaintiff from reporting to police, and included an affidavit from a UMBC employee who was in a meeting between Dillon and the student.

A 56-page, class action lawsuit filed Sept. 10 in federal court alleges a culture in Baltimore County — extending to the University of Maryland, Baltimore County, suppresses sexual assaults.

“At no time did Deputy Chief Dillon attempt to influence [the student] in her choice as to whether to file University Title IX charges, criminal charges or both,” wrote Rina Rhyne, who was then the program coordinator for Voices Against Violence and whose job it was to provide support to sexual assault victims.

In his own affidavit, Dillon stated that he explained the differences between filing a criminal complaint with the police and one under Title IX with UMBC. The criminal process involves a higher legal standard — that a prosecutor must show the alleged perpetrator is guilty “beyond a reasonable doubt.” UMBC’s Title IX process, Dillon stated, has a lesser standard, whereby the complainant would need to prove that the alleged perpetrator violated UMBC’s sexual misconduct policy by a “preponderance of the evidence.”

The memorandum in support of Dillon’s motion to dismiss also includes an email from Dillon to a Michael Peterson, who was then a Baltimore County police lieutenant in charge of the sex crimes division, informing him of the report of alleged sexual assault, but leaving out the student’s name as she had not yet decided to come forward.

Defendants in the lawsuit also include Baltimore County State’s Attorney Scott Shellenberger, the Baltimore County Police Department, UMBC and the Board of Regents for the University System of Maryland, among others.

According to a 2015 Clery crime report included in the filing, the UMBC student’s case was one of 10 cases of alleged forcible rape at the university. The Clery Act is a federal law requiring disclosure of crimes on or near campus. According to the court documents, two of the 10 were reported to Baltimore County police and both were classified as “unfounded.”

In response to the filing, the plaintiffs’ lawyer Rignal W. Baldwin V said, “I’m reviewing the motion and look forward to responding.”