The personal driver for Baltimore Ravens owner Arthur B. Modell filed a complaint yesterday with the U.S. Equal Employment Opportunity Commission claiming he was unjustly fired from his job after he took a week's medical leave.
An attorney for Jeffrey H. Dickson, 50, of Westminster, who has worked for Modell for more than six years, alleges that his client was wrongfully terminated because he could not transport Modell while taking narcotic painkillers prescribed by a physician.
"We believe that Mr. Dickson was wrongfully terminated because of a medical condition over which he had no control," said Dickson's attorney, Charles E. Brooks of Towson.
Before filing the complaint, Brooks said that he attempted to reach Ravens officials, including Modell's son, David. Brooks said he sent a certified letter to David Modell last month, "but we got no response."
Kevin Byrne, Ravens vice president for public and community relations, said yesterday that Modell would not address specific charges in the complaint. "Art's history of how well and fairly he treats his associates is well-known," Byrne said.
The EEOC investigates allegations of workplace discrimination stemming from disabilities, age, religion or ethnic background.
If the agency finds discrimination present, employers can be ordered to pay a former worker back pay, attorney's fees and court costs. Such action can strengthen a subsequent civil suit, said Brooks, who declined to say whether such a lawsuit would be filed.
Dickson was prescribed painkillers and a steroid medication July 20 for an infection in his mouth, sinuses and lips, according to the EEOC complaint. Directions for using the narcotic, Percocet, specify that the patient refrain from driving and using machinery.
While off from work for a week, Dickson telephoned the Ravens front office daily and informed them of his progress, the complaint says.
On July 26, he contacted a front-office employee and told her that he was no longer taking the medication and was ready to return to work, according to the complaint.
Dickson called the Ravens front office each workday until, on Aug. 5, he was told that Modell would not need a driver until further notice.
Two days later, Dickson was told to report to the team's training facility in Westminster to meet with David Modell, Ravens president and chief executive officer.
At the meeting, Dickson was told that he was fired and to return team property, including credit cards, cellular telephones, pagers and keys. He was given a separation agreement to sign that would have granted him eight weeks severance pay, the complaint says.
A signed agreement would have prevented Dickson from going public with details about the termination or bringing legal damages against Modell or the football team.
Dickson declined to sign, and sought legal counsel. "I couldn't agree to that, it was so insulting," he said. "My boss [Arthur Modell] didn't even have the decency to talk with me, call me once, about how I was doing when I was sick."
Dickson, a former contractor in the transportation business, said that he was "considered part of Mr. Modell's family. When I drove him, he sat in the front seat with me. We joked with each other, we were like buddies."
As proof of Dickson's illness, the complaint notes that Dr. Andrew Tucker, the Ravens physician, dispensed medication to Dickson. The former driver also documented a visit to the Carroll County General Hospital emergency room the night before he called in sick.