INVESTIGATIO N REPORT

TO: VILLAGE OF MAYWOOD BOARD OF TRUSTEES

FROM: CARRIE A. HERSCHMAN, ESQ.

SUBJECT: CONFIDENTIAL WORKPLACE INVESTIGATION

DATE: JUNE 2, 2022

EXECUTIVE SUMMARY
On March 22, 2022, Village Manager Chasity Wells-Armstrong made a complaint
to the Village of Maywood Board of Trustees alleging that Mayor Nathaniel Booker was
subjecting her to a hostile work environment and overstepping his Article 5 statutory
authority. She also claimed that former Village Attorney Michael Jurusik participated in
Mayor Booker’s alleged misconduct. Village Manager Wells-Armstrong thereafter fired
Mr. Jurusik on March 25, 2022 and replaced him with Felicia Frazier and Burt Odelson of
Odelson, Sterk, Murphey, Frazier & McGrath, Ltd.
In response to the complaint, the Trustees engaged Carrie Herschman of
Herschman Levison Hobfoll PLLC on April 6, 2022 to conduct an independent
investigation into the Village Manager Wells-Armstrong’s allegations and to make
appropriate recommendations. Ms. Herschman was provided full access to Village
employees and its officials and she interviewed twenty five individuals during the
investigation. Ms. Herschman attended a portion of a Board meeting in person and watched
Board meetings online. This report is based on the interviews conducted, the documents
reviewed, Board meetings, and legal research into the complaint and allegations.
As described in greater detail below, the investigation found no evidence
supporting the Village Manager Wells-Armstrong’s allegations of a hostile work
environment based on a protected characteristic. The complaint about Mayor Booker
overstepping his Article 5 statutory authority alone does not constitute an actionable claim
of discrimination.
Rather than uncovering evidence supporting her complaints, the investigation
found a culture of fear and intimidation in Maywood created by Village Manager Wells-

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Armstrong. In particular, numerous individuals expressed fear of retaliation from Village

Manager Wells-Armstrong. Because so many people voiced concerns about potential
retaliation, the facts are presented in narrative form and names and identifying information
of individuals interviewed are not used.
The investigation further found that Village Manager Wells-Armstrong engaged in
discriminatory conduct. Notably, multiple people reported that Village Manager Wells-
Armstrong made disparaging remarks about race and perceived sexual orientation.
Witnesses also reported that Village Manager Wells-Armstrong frequently threatened to
physically harm Mayor Booker when expressing her feelings toward him. Although she
never directly threatened Mayor Booker, using such language to express her feelings
towards the Mayor (especially when speaking with subordinates) is inappropriate and
unprofessional. In contrast, Mayor Booker did not express, nor did anyone report that he
used aggressive language when describing his feelings towards Village Manager Wells-
Armstrong.
It is my recommendation that the Board of Trustees terminate Village Manager
Wells-Armstrong’s employment because of her retaliatory behavior towards employees
and her use of discriminatory language and tropes to describe her perceived opponents. I
also recommend that Maywood establish the Commission on Community Relations and
update Maywood’s Personnel Manual so Village employees and others may report their
concerns about discrimination and retaliation, among other things, without fear of
retribution.

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THE VILLAGE MANAGER’S COMPLAINTS AGAINST THE MAYOR

Village Manager Chasity Wells-Armstrong (the “Village Manager”) first
complained in writing on March 22, 2022 following Mayor Nathaniel Booker’s (the
“Mayor”) unsuccessful attempt to end her employment during a closed executive session. 1
The Village Manager sent a memo with the re: line “First three (3) Quarters and Goals for
FY’23” to some – but not all – of the Trustees 2 that included claims against the Mayor. She
generally alleged that the Mayor had created a hostile work environment and that he had
overstepped his authority. For example, she complained that “her personal space has been
encroached upon without regard for my feelings or impact on staff.” The Village Manager
described her relationship with the Mayor as an “abusive relationship” and suggested that
the Mayor suffers from an “abusive personality.” The Village Manager read her complaint
to Board of Trustees during an executive session.
The Village Manager made a further written complaint against the Mayor in a
memo dated March 25, 2022.3 That memo had the re: line “Appointment of the Village
Attorney” and explains the Village Manager’s decision to fire the then Village Attorney,
Michael Jurusik, and hire Felicia Frazier and Burt Odelson to replace him as the Village
Attorney. The memo restates the Village Manager’s general belief “regarding the hostile
work environment that has been created because of Mayor Nathaniel George Booker
consistently violating the Article 5 form of government” and reasserts that the Village
Manager “no longer feel[s] comfortable engaging with Mayor Booker or Attorney
Jurusik.” The Village Manager claims that “Attorney Jurusik has not only allowed Mayor
Booker to operate outside the Village’s Statutory Manager form of government, but has
participated in the intimidation tactics of an employee, thus perpetuating a hostile work
environment.” (Emphasis original.)
Later the Village Manager suggested that the Mayor mistreated her due to her
gender noting that she was the first female village manager. She also subsequently alleged
that the decision to await the results of the investigation before taking action on leasing a

1
A copy of the Village Manager’s March 22 allegations and accompanying materials are attached
hereto and incorporated herein as Exhibit A.
2
The Village Manager said she deliberately excluded Board members she believed were the
Mayor’s supporters.
3
A copy of the Village Manager’s March 25 allegations and accompanying materials are attached
hereto and incorporated herein as Exhibit B.

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car for her and before reviewing her performance constituted acts of retaliation against
her.4
THE INVESTIGATION
I. Complainant’s Interview
As discussed on April 6, 2022 during closed session, I sought to interview the
Village Manager, the complainant, first. Interviewing the complaining party is always the
first step in an investigation. I offered to interview the Village Manager on a date and time
that was convenient for her. She declined my offer to interview her over the weekend or
outside of business hours. Village Manager Wells-Armstrong was adamant that she would
not cooperate if I was associated with the former Village Attorney. Following assurances
that I was, in fact, independent, and not affiliated with the law firm of Klein, Thorpe &
Jenkins, she agreed to be interviewed – but not until April 29, 2022. Less than 24 hours
before her April 29 interview, the Village Manager sought to reschedule the interview in
order to attend a ComEd event claiming that the Mayor would “hold it against her” if she
did not attend the event.5
In the end, the Village Manager appeared for her April 29 interview after a Trustee
intervened. My attempts to schedule a follow-up interview with her were likewise met with
resistance. The follow-up interview eventually took place on May 31, 2022. Despite the
difficulties in interviewing her, the Village Manager sent me more than seventy emails
throughout the investigation that she asserted support her claims.
In contrast, Mayor Booker made himself readily available for interviews and
uploaded documentary support for his position through a secure link I provided. He also
forwarded emails throughout the investigation. Mayor Booker sent me more than fifty
emails throughout the investigation to support his position.

4
The Village Manager and Village Attorney Burt Odelson each notified this investigator about the
Mayor’s recent arrest for driving under the influence which the Mayor confirmed happened. For
purposes of this Report, the Mayor’s arrest was neither considered nor given any weight because
Illinois has a strong public policy prohibiting employers from considering arrest records and
conviction records when making employment decisions. See 775 ILCS 5/2-103 (arrest record) and
775 ILCS 5/2-103.1 (conviction record). A copy of relevant portions of the laws are attached hereto
and incorporated herein as Exhibit C.
5
The email correspondence the Village Manager provided in support of her position undercut her
claims that the Mayor was acting against her and/or that she only recently learned of the conflict.
A copy of the email correspondence is attached hereto and incorporated herein as Exhibit D.

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II. Witness Interviews

I interviewed every Trustee, and most of the department heads. I also spoke with
lower level employees, the former and new Village Attorneys, and third party witnesses.
Some witnesses were interviewed more than once. Each of the witnesses made time to
speak to me; however, I repeatedly had to address concerns about retaliation throughout
the interviews. Some witnesses simply refused to speak to me citing their concerns of
retaliation from the Village Manager. All the witnesses who feared retaliation were the
Village Manager’s subordinates. None of the witnesses were concerned about retaliation
from the Mayor. Those witnesses that feared retaliation would only speak to me after they
were assured several times that their names would not be used in the report and that they
would not be otherwise identified. It is for this reason that witness names are not used in
the report and the facts are presented in narrative form.
BACKGROUND
I. Maywood’s Managerial Form of Municipal Government
In 1979, the Village of Maywood adopted the managerial form of municipal
government as set forth in Article 5 of the Illinois Municipal Code. 6 Consistent with Article
5, the mayor is the official head of Maywood and has the right to vote on legislative
matters 7 while the village manager is the administrative head of Maywood and responsible
for the efficient administration of all Maywood departments. 8
Maywood is governed by a Board of Trustees consisting of a mayor9 and 6
trustees. 10 The Board of Trustees is the legislative body responsible for enacting all
ordinances. 11
The village manager reports to the Board of Trustees and serves at the Board’s
discretion. The Board of Trustees appoints the village manager and sets the conditions of
the village manager’s employment.12 The village manager may be removed from office at

6
See Maywood Municipal Code § 30.25; see also 65 ILCS 5/1-1-1, et seq. Relevant provisions of
the Illinois Municipal Code are attached hereto as Exhibit E.
7
65 ILCS 5/5-3-1.
8
65 ILCS 5/5-3-7.
9
“The president of a village or incorporated town may be referred to as mayor or president of
such village or incorporated town.” 65 ILCS 5/1-1-2.1.
10
Id.
11
65 ILCS 5/5-3-6.
12
Id.

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any point by a majority vote of the Board of Trustees. 13 Thus the Board of Trustees retains
the power to fire the village manager consistent with the employment contract.
The village manager should be apolitical and is responsible for the day-to-day
operations of Maywood. 14 As the administrative head, the village manager has the
following statutory powers and duties:
1. To enforce the laws and ordinances within Maywood; 15
2. To appoint and remove all directors of departments; 16
3. To exercise control of all departments and divisions within Maywood; 17
4. To prepare financial data for the Board of Trustees to consider prior to
preparation of the annual appropriation ordinance; 18
5. To attend all Board of Trustees meetings with the right to take part in
discussions, but with no right to vote on any question or ordinance; 19
6. To recommend to the Board of Trustees for adoption such measures as she
may deem necessary or expedient; 20 and,
7. To perform such other duties as may be prescribed by Article 5 or may be
required by the Maywood Municipal Code or resolution of the Board of
Trustees. 21
II. The Current Mayor, Board of Trustees and Village Manager
The Maywood Board of Trustees (the “Board of Trustees”) consists of six
individual Trustees and the Mayor. All the Trustees are impressive in their own right –
each of whom has dedicated their personal time and energy to the Village of Maywood.
The Trustees are all eager to make Maywood a better place for their constituents, their
families, and themselves.
Mayor Nathaniel Booker is a first-term Mayor. Prior to being elected mayor, he
served the Village of Maywood as a Trustee. Mayor Booker’s hand-picked Village
Manager was Chasity Wells-Armstrong, a former one-term mayor of Kankakee. Ms.

13
Id.
14
The village manager is “appointed without regard to his political beliefs.” 65 ILCS 5/5-3-7.
15
65 ILCS 5/5-3-7(1).
16
65 ILCS 5/5-3-7(2).
17
65 ILCS 5/5-3-7(3).
1818
65 ILCS 5/5-3-7(5).
19
65 ILCS 5/5-3-7(6).
20
65 ILCS 5/5-3-7(7).
21
65 ILCS 5/5-3-7(8).

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Wells-Armstrong had not worked as a village manager prior to her hiring. Witnesses noted
that she was “barely qualified” 22 for the role, and that her hiring was outside the normal
procedure. The Mayor selected the Village Manager without presenting any other
candidates to the board. Normally a national search for a village manager would be
conducted, and the Board of Trustees would have the opportunity to interview multiple
candidates. Instead, the Mayor elected to forego this process in favor of Ms. Wells-
Armstrong.
It was against this backdrop that the Village Manager moved her family from
Kankakee to Bolingbrook to take the instant job, having just lost her bid for reelection in
Kankakee. Initially, the relationship between the Mayor and the Village Manager was
strong. All witnesses agreed that the relationship between the Mayor and the Village
Manager was very good in the beginning – describing them as “besties” and expressing
surprise at the demise of their relationship.
The Village Manager and the Mayor were aligned in hiring and firing decisions,
save one. The Village Manager sought from the start to replace the former Village Attorney
with the attorneys she used in Kankakee. The Mayor objected, wanting to keep the former
Village Attorney, who had held the role for twenty years.
The Village Manager followed the Mayor’s direction and the former Village
Attorney continued in his role. However, the Village Manager continued to contact the
former Kankakee attorneys. 23 She would call Burt Odelson throughout her employment to
get his advice on matters. Mr. Odelson provided “free legal advice” in his words, to the
Village Manager, advising her about the respective roles of the Mayor as compared to the
Village Manager under the managerial form of municipal government. The Village
Manager complained to Mr. Odelson that she was being subjected to a “hostile work
environment” because of the Mayor’s actions. Mr. Odelson advised her to try to work with
the Mayor and that if she could not, she should raise her complaint with the Board of
Trustees.
The relationship between the Mayor and the Village Manager began to unravel in
the late summer/early fall 2021. The Village Manager alleges that problems began when
she refused to do the Mayor’s bidding and stood up for herself. The Mayor alleges that
their relationship deteriorated after he identified numerous problems with her work.

22
Ms. Wells-Armstrong’s resume and the village manager job description are attached hereto and
incorporated herein as Exhibit F.
23
Burt Odelson previously worked with the Village Manager when she was the mayor of Kankakee.

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The Village Manager repeatedly sought assurances from the Mayor that her two-
year contract would be extended, but the Mayor would not provide her assurances because
he believed her job performance was subpar. He was dissatisfied with her ability to
complete tasks 24 – many of which the Board of Trustees had previously assigned to the
prior Village Manager. He was also dissatisfied with her failure to make good on his
campaign promises. Among other things, resident concerns remained unaddressed on the
MyCivic application, although the Board of Trustees had previously directed that all
concerns should be acknowledged within 48 hours of receipt. The Mayor was also
frustrated that the Zetron system was not yet functional. The Mayor was further critical of
the Village Manager for problems with the Village’s website. In an effort to repair the
relationship, the Village Manager asked the Mayor to go to Michigan – where she had
frequently vacationed – so they could concentrate on resetting their relationship. The
Mayor agreed.
The trip, which the Village Manager paid for herself, was a failure. The Village
Manager recounts how the Mayor chose to listen to his car navigation system rather than
her directions to the location – an example she claims that demonstrates how the Mayor
does not listen to others. 25 The Mayor was uncomfortable with the trip from start to finish
– he didn’t understand why they needed to go to Michigan. Very little time was spent on
Village business of any kind – the Village Manager described the trip as a “reset” one that
could help her and the Mayor understand one another better. The Mayor found the Village
Manager’s personal questions – her attempt to better understand and connect with the
Mayor – strange and uncomfortable.
After the Michigan trip, the Mayor and the Village Manager met with Village
Attorney Jurusik. 26 At this point, according to all of the parties, the relationship between
the two was effectively over. The Mayor and the Village Manager could barely speak on
the phone to one another. Village Attorney Jurusik advised them to find a way to work it
out – to communicate via Mycivic or email.
The Village Manager eventually blocked the Mayor from her personal cell phone.
During her initial interview on April 29, she stated that she could not and would not speak
to the Mayor. When questioned on how that could possibly work, she suggested that she

24
The Village Manager’s self-appraisal and the Mayor’s comments thereto as well as the points he
sought to address with the Board regarding the Village Manager’s performance are attached hereto
and incorporated herein as Exhibit G.
25
This complaint was echoed by many Trustees, including members of the Mayor’s own political
party.
26
The Mayor and the Village Manager met with the Village Attorney on 2-3 occasions.

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could have a meeting with the Mayor so long as the meeting was also attended by certain
Trustees, Isiah Brandon, Miguel Jones, Aaron Peppers and Shabaun Reyes-Plummer,
whom she believed were “against” the Mayor. After some coaxing she agreed that meetings
with the Mayor must include all the Trustees. Nonetheless, she flatly refused to meet with
the Mayor individually. Later during the interview, she said that she was willing to shake
the Mayor’s hand publicly and move forward.
The Mayor was not so inclined. The Mayor cannot envision a path forward because
he believes the relationship is damaged beyond repair.
The Village Manager sought advice about the Mayor and her relationship from
different sources – the former Village Attorney, the new Village Attorneys and some
Trustees, among others. As noted above, Mr. Odelson, one of the new Village Attorneys,
stated that he provided Ms. Wells-Armstrong “free legal advice” prior to replacing the
former Village Attorney.
The former Village Attorney attempted to mediate the deteriorating relationship
between the two and encouraged the Village Manager and the Mayor to find a way to work
together. Because phone calls were unproductive, Village Attorney Jurusik suggested that
they communicate via email and MyCivic. Village Attorney Jurusik reminded the Village
Manager that she, like him, was an “at will” employee, meaning she could be fired at any
time, for any reason, absent an unlawful reason. The Board of Trustees could fire her at
any point, provided a majority voted in favor of her removal. The at-will nature of the
employment relationship is explicitly stated in the Village Manager’s contract27 and is

27
“Section 3. AT WILL EMPLOYMENT RELATIONSHIP. CWA [Chasity Wells-Armstrong]
agrees and understands that her employment relationship with the Village is an “at-will”
relationship and the Corporate Authorities may terminate her and this Agreement at any time and
for any reason. CWA agrees and understands that she does not have the right to receive any type
of progressive discipline prior to the termination of this Agreement, and she waives any and all
claims to a contract right of employment having been created by this Agreement or any Village
Code provision or the Village of Maywood’s Personnel Policy Manual or any State law. Nothing
in this Agreement shall prevent, limit or otherwise interfered with the rights of the Corporate
Authorities to terminate the employment of CWA at any time, subject only to the provisions set
forth herein. Nothing in this Agreement shall prevent, limit or otherwise interfere with the rights of
the Corporate Authorities to terminate the employment of CWA at any time, subject only to the
provisions set forth herein. Nothing in this Agreement shall prevent, limit or otherwise interfere
with the right of CWA to terminate her employment with the Village at any time, subject only to
the provisions herein.” Contract, page 3. A copy of the Village Manager’s contract is attached
hereto and incorporated herein as Exhibit H.

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consistent with Article 5 of the Illinois Municipal Code. 28 At that time, the Village Manager
again brought up a contract extension. The former Village Attorney advised her that her
contract could not extend beyond the Mayor’s term as a matter of law. 29 Ultimately, the
Village Manager would fire Village Attorney Jurusik.
But first, the Mayor attempted to fire the Village Manager at a special board
meeting on March 9 which was unsuccessful. The Village Manager then made the instant
allegations on March 22 and March 25 against both the Mayor and the former Village
Attorney.
ANALYSIS AND FINDINGS
I. Alleged “Hostile Work Environment”
The Village Manager repeatedly uses the term “hostile work environment” to
describe her complaints against the Mayor. She uses that term in the lay sense not as the
concept is understood under the law. In order to state a claim for a hostile work
environment, the employee must demonstrate that the alleged hostile work environment is
based on a protected characteristic – for example, race, gender, and/or age - that is so severe
and pervasive it alters the workplace. 30 Here, the Village Manager fails to allege any
discriminatory conduct that would be actionable under state and/or federal law.

28
65 ILCS 5/5-3-7.
29
65 ILCS 5/8-1-7(b) states, in relevant part, “…the corporate authorities of any municipality may
make contracts for a term exceeding one year and not exceeding the term of the mayor or president
holding office at the time the contract is executed, relating to (1) the employment of a municipal
manager…”
30
The Equal Employment Opportunity Commission (“EEOC”) defines harassment and a hostile
work environment this way: “Harassment is unwelcome conduct that is based on race, color,
religion, sex (including sexual orientation, gender identity, or pregnancy), national origin, older age
(beginning at age 40), disability, or genetic information (including family medical history).
Harassment becomes unlawful where 1) enduring the offensive conduct becomes a condition of
continued employment, or 2) the conduct is severe or pervasive enough to create a work
environment that a reasonable person would consider intimidating, hostile, or abusive.”
www.eeoc.gov/harassment. The Illinois Human Rights Act, 775 ILCS 5/1-101 et seq., uses this
definition, “5/2-101 (E-1) Harassment. "Harassment" means any unwelcome conduct on the basis
of an individual's actual or perceived race, color, religion, national origin, ancestry, age, sex, marital
status, order of protection status, disability, military status, sexual orientation, pregnancy,
unfavorable discharge from military service, citizenship status, or work authorization status that
has the purpose or effect of substantially interfering with the individual's work performance or
creating an intimidating, hostile, or offensive working environment. For purposes of this definition,
the phrase "working environment" is not limited to a physical location an employee is assigned to

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a. March 22 allegations
In her March 22 memo, the Village Manager writes, “Prior to the special board
meeting the Mayor called on March 9, 2022, I could sense our relationship was on a
negative decline. I knew he was not happy with my constantly pushing back and reminding
him I have seven (7) bosses. In prior weeks, I even asked him if he was going to “Willie
Norfleet” (fire) me.” The Village Manager’s statement that she was aware of the Mayor’s
concerns about her performance prior to her complaint undercuts general claims of
workplace misconduct because she only made those claims after she learned the Mayor
was dissatisfied with her job performance and not interested in discussing a contract
extension. 31 Moreover, the Village Manager serves at the discretion of the Board of
Trustees and the Mayor, as a member of that Board, was properly concerned with her job
performance.32
The Village Manager also claimed that the Mayor accused her of siding with his
political opposition.33 The position of village manager is supposed to be apolitical, but it is
clear that Village Manager Wells-Armstrong acted politically when dealing with the
Mayor. 34 Although the Village Manager produced one email to support her claim, it is my
opinion that the Village Manager, not the Mayor, has weaponized the deep political divides
in Maywood and politicized the office of the Village Manager. For example, on March 22
she provided the attached Exhibit A outlining her concerns, to some – but not all – of the
Board of Trustees. She admitted that she excluded certain Trustees that she believed were
“with” the Mayor.
Furthermore, throughout this investigation, the Village Manager elected to forward
emails to me that she believed supported her claims against the Mayor. The emails she
provided did not demonstrate that the Mayor was mistreating her. Instead, the emails she
provided demonstrated that she, not the Mayor, sought to weaponize the political divides
in Maywood. She alerts some – but not all – of her seven bosses to perceived wrongdoing,
regularly speaking to Trustees Brandon, Jones and Peppers and refusing to speak to
Trustees Lightford, Sanchez and Booker.

perform his or her duties. A copy of the relevant statutory provisions is attached hereto and
incorporated herein as Exhibit I.
31
Had the Village Manager contacted me for legal advice, I would have advised her to do precisely
what she did here – file a complaint in order to slow down the termination process.
32
65 ILCS 5/5-3-7.
33
The Village Manager provided an email to support this allegation. The email is attached hereto
and incorporated herein as Exhibit J.
34
65 ILCS 5/5-3-7.

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b. March 25 Allegations
The Village Manager’s March 25 allegations expand upon her claim of a hostile
work environment, claiming that the Mayor, together with the former Village Attorney,
violated the “Article 5” form of government – that is, where the Village Manager is tasked
with day-to-day operations.
The Village Manager articulates no actionable claim here. Instead, she has provided
one of the most striking examples of how her personal animosity towards about the Mayor
impacted the Village of Maywood.
She has directed staff not to speak to the Mayor upon pain of discipline.35 She has
demonstrated that she can, does and will retaliate against anyone who does not follow her
directions. She has told multiple witnesses that she wants to “punch the Mayor in the face”
that she will “whoop his ass” and that he belongs in the basement. No witness corroborated
her statement that the Mayor yelled at her.
The relationship between the Mayor and the Village Manager in the Manager form
of local government can be complex. The Village Manager essentially argues that the
Mayor has acted ultra vires – or overstepped his authority – by inserting himself into day-
to-day Village operations. She then complains that the former Village Attorney supported
his efforts to undermine her authority.
The Village Manager could not point to any evidence that the former Village
Attorney aided the Mayor in this alleged power grab. The evidence demonstrated that the
Village Attorney provided training to the Village Manager, Mayor and Board of Trustees
regarding their respective roles and that he provided her with correct legal advice, albeit
legal advice that she disliked. At the beginning of her employment, the Village Manager
sought to hire Odelson, Sterk, McGrath & Frazier as the Village Attorneys. She had
previously worked with Burt Odelson and Felicia Frazier while she was the Mayor of
Kankakee. The Mayor did not want to fire the longtime Village Attorney, and the Village
Manager ceded to his request. Mr. Odelson stated that he had provided Ms. Wells-
Armstrong “free legal advice” throughout her employment with the Village of Maywood
on the respective roles of the mayor and the village manager in an Article 5 form of
government prior to becoming the Village Attorney. 36 He also stated that she had told him

35
The Village Manager’s April 12 communication and memo are attached hereto and incorporated
herein as Exhibit K.
36
The Village Manager’s May 31 email that her relationship with the lawyers is no one’s business
is attached hereto and incorporated herein as Exhibit L. I did not find that the Village Manager
contacted four trustees prior to making her decision.

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that she believed she was being subject to a hostile work environment and that he advised
her to try to work it out with the Mayor but that if she could not she should tell the Board
of Trustees.
In his 2021 Training Session for Appointed and Elected Village Officials the former
Village Attorney advised the Village that “Village Manager form of gov’t => appointed
and elected officials do not direct Village employees… the Village Manager does.” 37 The
International City/County Management Association, (“ICMA”) states that “it is a
fundamental principal of the council-manager form of government that council members
will not direct staff other than through the manager. In some cases, all direct contact is
discouraged. In other cases, asking questions is considered acceptable, particularly if
directed at higher level employees such as department heads.” 38 The former Village
Attorney provided an article39 he distributes to all his municipal clients that operate under
the Village Manager form of government that describes the interaction between the office
of the mayor and the office of the Village Manager. The article states, among other things:
“[The mayor] also serves as spokesman for the council, enunciating
positions taken, informing the public about coming business, and fielding
questions about the city’s policies and intentions.” (Emphasis original)
(page 2)
“Although the manager must maintain positive relationships with each
member of the council, the mayor-manager interaction is an official way to
exchange information...” (page 4)
“For example, the mayor may advise the manager to bring more matters to
the council or fewer; he may intervene with a council member who is
intruding into operational matters, or he may seek to alleviate tension
between the council and staff before a series [sic] develops.” (page 4)
The quoted passages all envision a government where the mayor and village manager work
together to move the elected official’s agenda forward. The Village Manager’s argument
that the Mayor is to have no contact with any staff – upon pain of discipline – and insistence
that she receive direction from “all seven of her bosses” fosters political infighting and
renders any Village business virtually impossible to conduct. The political divisions in
Maywood are well-known. Furthermore, the evidence that the Village Manager provided

37
A copy of the relevant portion of the presentation is attached hereto as Exhibit M.
38
“Making it Work: The Essentials of Council-Manager Relations” ICMA at 21.
39
A copy of the article the former Village Attorney provided is attached hereto and incorporated
herein as Exhibit N.

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shows that she has not sought the advice of all seven of her bosses but rather selectively
sought the advice of the Mayor’s political opponents. In so doing she has politicized the
office of Village Manager – a role that should be apolitical. See, e.g., the attached memo
drafted by Mr. Odelson which states, “The Illinois Municipal Code stresses the non-
partisan nature of the manager’s role in that the manager is ‘appointed without regard to
his [or her] political beliefs.’ The emphasis is consistently on the professional skill and
managerial competence of the manager. Policy and politics are the province of the Council
or Village Board, not the manager.” 40
The former Village Attorney correctly advised the Village Manager and Mayor that
her contract could not extend beyond the Mayor’s term, which ends in April, 2025.41 The
Village Manager is certainly within her authority to appoint the Village Attorney. That
said, when the Village Manager exercises that authority in a strategic, retaliatory manner
to serve her own interests she acts improperly.
Here, she fired the former Village attorney, who had served the village for over
twenty years and holds a great deal of institutional knowledge about the Village. The
Village Manager apparently never accepted the former Village Attorney and wanted to
have her own people in place. Throughout her employment she sought advice from Mr.
Odelson and elected to fire the Village Attorney after she received advice she did not like.
As one Trustee asked, “who is Felicia Frazer? Is she the Village’s attorney or Chasity’s
personal attorney?” 42
The Village Manager’s other allegations, that the Mayor has exceeded his statutory
authority likewise fail. The Mayor is well within the scope of his authority to meet Village
employees and ask questions. He can observe staff meetings; he cannot direct Village staff.
There has been no evidence presented that the Mayor interfered with or otherwise directed
staff in violation of Article 5. To the contrary, the Village Manager has politicized her
office to such an extent that Village employees fear her, not elected officials.

40
A copy of the memo is attached hereto and incorporated herein as Exhibit O.
41
65 ILCS 5/8-1-7(b) states, in relevant part, “…the corporate authorities of any municipality may
make contracts for a term exceeding one year and not exceeding the term of the mayor or president
holding office at the time the contract is executed, relating to (1) the employment of a municipal
manager…”
42
I did not find any evidence that Ms. Frazer placed the Village Manager’s interests above those
of the Village. The Village Manager did forward me and the Village Attorney (Ms. Frazer and Burt
Oldeson) emails that should have been addressed only to me. Those emails involved the
investigation and her allegations are attached hereto as Exhibit P.

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The Village Manager’s written directive prohibiting Village employees from

speaking to the Mayor – or any other Village official – means that no Village employee
could report concerns about the workplace, the Village Manager or their fears of retaliation
to her employer.
When asked to expand upon her March 22 and March 25 allegations, the Village
Manager provided no relevant evidence. She was unable to state, for example, how the
Mayor had allegedly overstepped his authority. I pressed her for examples of how he
interfered with the Village’s day-to-day operations. In response, she simply concluded that
he did. Village Attorney Burt Odelson commented that the Mayor exceeded his authority
by sitting in the Village Manager’s meetings with department heads but later conceded that
the Mayor, as well as the Trustees, could attend those meetings as observers. 43 There is no
evidence that the Mayor hired or fired department heads or otherwise usurped any of the
other statutory powers of the Village Manager.
II. The Village Manager Retaliates Against Village Employees
In the course of investigating the Village Manager’s complaint, I discovered serious
concerns about how the Village Manager conducted herself in her day-to-day functions.
Numerous witnesses reported that the Village Manager used derogatory terms, displayed
discriminatory intent and/or engaged in retaliatory behavior against Village employees.
The Village Manager’s retaliatory behavior is well documented. Nearly every
witness (including a Trustee) was fearful of speaking to me. Some employees simply
refused to be interviewed, including a department head. Witnesses would only speak to me
after they were assured several times that their names would not be used in the report and
that they would not be otherwise identified. I have conducted many workplace
investigations and have never encountered a workforce like this one, that is uniformly
afraid to cooperate with me. Retaliating against a witness who participates in an
investigation such as the instant investigation states a claim for retaliation under both state
and federal law. Moreover, retaliation claims account for more than half of all employment
discrimination claims filed at the EEOC.44
Examples of retaliation from the Village Manager include, but are not limited to,
the following:

43
Village Attorney Burt Odelson acknowledged that neither he nor any Odelson Sterk attorney ever
raised concerns to the Board of Trustees about the Mayor exceeding his statutory authority.
44
Retaliation claims account for 55.8% of all charges filed with the EEOC according to the EEOC’s
enforcement and litigation data for the 2020 fiscal year.

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o When a department head answered a question from the Mayor at a COW

meeting that the Village Manager did not like she ordered him to move his
office to the basement;
o When the Mayor told the Village Manager that graffiti in the Village needed
to be removed at a Board meeting the Village Manager reneged on the plan
to hire a laborer to assist in the Department, telling the Department head
that she would hire him an assistant deputy instead in order to keep an eye
on him [the department head];
o The Village Manager removed a Department Head from the weekly
meetings she had with Department Heads because she believed the
individual was providing the Mayor information;
o The Village Manager placed a Department Head on a three-day unpaid
suspension for disagreeing with her privately;
o The Village Manager moved offices of Village employees she believes were
aligned with the Mayor to punish them; and,
o The Village Manager publicly shames and berates Village employees she
believes are “disloyal” to her.
In contrast, no Village employee alleged that they were subject to retaliation from
the Mayor. Some employees expressed concern about being caught in the politics of this
investigation, but when asked directly if they feared retaliation from the mayor, all
answered they did not. In contrast, when asked if they feared retaliation from the Village
Manager all but two answered affirmatively. Nearly every employee cried during their
interviews with me. All the employees were anxious about their jobs and fearful of what
the Village Manager might do to them in retaliation for speaking to me. In this form of
government, the Village Manager, not the Mayor, Maywood’s administrator with the
absolute power to hire and fire Village employees, a fact that is well known to all. As the
Village Manager angrily told a Village employee, “I can fire you and there is not a damn
thing the Mayor can do about it.”
III. The Village Manager Uses Discriminatory Language and Tropes
Multiple employees stated that the Village Manager used foul language and
discriminatory language regularly when referring to her perceived opponents. I had the
same experience during our first interview. While no question was pending, and I was
taking notes, the Village Manager offered that, “the Mayor has gender identity issues” as
a reason that they could not work together. This homophobic, transphobic language plays

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to the implicit bias 45 of Trustees. One Trustee said that the Mayor was too “emotional” and
did not act the way a man should. Implicit bias – how to identify it, address it and overcome
it, has become increasingly important in the workplace and beyond. For example, Illinois
state court judges are now required to complete implicit bias training. 46
Employees described multiple occasions wherein the Village Manager utilized
racist and sexist tropes. Among other things, she would warn employees that they could
have “momma” who would take care of them, or “black momma” who would “whoop their
ass”. She told employees that the problem really was that they were white and management
was black – minimizing concerns and infusing the Village’s day-to-day operations with
discriminatory, divisive language.
The Village Manager likewise employs homophobic tropes and slurs to describe
the Mayor. One witness recounted how she told him that she would not, “take orders from
a well-groomed black man” because she would prefer to “punch him in his f_ing face”. 47
She has told multiple employees as well as third parties that she wants to “punch
the mayor in the face” 48 and that she wants to “whoop his ass”. 49
She has repeatedly stated that the mayor is simply “part time”,50 without
acknowledging that is offensive. She maintains that is not derisive but that she is simply
stating “facts”. She regularly opines that she would never live in Maywood, refusing to
acknowledge how offensive that statement is. She says that the Mayor is not “her” Mayor,
arguing that is a fact because she does not live in Maywood. She states that she does not
want to be in politics, and that the Mayor publicly demeans and discredits her while

45
Implicit bias refers to the attitudes and stereotypes that affect our understanding, actions and
decisions in an unconscious manner. State of Science: Implicit Bias Review 2015. Kirwan Institute
for the Study of Race and Ethnicity.
46
See “Interrupting Implicit Bias in the Illinois Judiciary”, https://www.2civility.org/interrupting-
implicit-bias-in-the-illinois-judiciary/.
47
The phrase “well-groomed black man” is used to refer to black men who are – or perceived to be
– homosexual.
48
Threats against public officials are expressly prohibited by state law. 720 ILCS 5/12-9 (stating
that it is a Class 3 felony for the first offense and a Class 2 felony for a second offense). A copy of
the law is attached hereto and incorporated herein as Exhibit Q.
49
No Trustee had heard the Village Manager use this language; no Village employee had brought
their concerns about the Village Manager’s use of derogatory language and/or tropes. This is
unsurprising – the Village Manager has made clear that employees who contact any elected officials
– i.e. her supervisors – will be subject to immediate discipline. Additionally, the Village has not
yet established a Commission on
50
Include copies of emails wherein she refers to the mayor as “parttime”.

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likewise ignoring her role in fostering political division. Maywood’s managerial form of
municipal government only works if the Village Manager is not partisan. Here, the Village
Manager is nothing but partisan. She has effectively rendered the office of the Mayor
superfluous, anointing herself the de facto mayor without the bother of an election.
In her written allegations to the Board she alleges that the Mayor is a narcissist who
has a personality disorder.51 She told me that she knew this was the case because she had
worked with addicts for years. In the packet she provided to the Mayor’s political
opponents she included an article on how to identify such personality disorders. Such
conduct is inappropriate and demeaning. The Village Manager is not qualified to render
psychiatric opinions and even if she was qualified it is unethical to speculate about the
mental health of public figures.52
Likewise, her behavior at Board meetings and the materials she chooses to
showcase at the meetings are inappropriate and disrespectful of others’ time. When I asked
her why she would opt to include a Ted Talk on civility in her report at a Board meeting
that was already past 11 p.m. she stated that it was not directed at the Mayor but rather at
the residents who attended the meetings. In either scenario her judgment is fundamentally
flawed. Ultimately, she serves Maywood residents and is obligated to listen to their
concerns. She is certainly not the only person who is disrespectful of others’ time – some
Trustees and the Mayor exhibit the same behavior. Board meetings become shouting
matches between the Village Manager, the Mayor, and his political rivals. The Mayor and
certain Trustees are often incapable of moving forward and fight to get the last
(unnecessary) word in. While this lack of courtesy among political rivals is not unique to
Maywood, the role of the village manager is meant to be nonpartisan.
IV. Village Officials Fail to Listen to One Another
Insisting that she is not in politics while refusing to take direction from the Mayor
enables the Village Manager to weaponize the deep political divides in Maywood for her
own gains. Every Trustee, including the Mayor, expressed his shock that Trustee Reyes-
Plummer – the Mayor’s “girl” – would vote against his March 22 request to end the Village
Manager’s employment. The idea that a Trustee would make a decision based on their own
view of the matter at hand – rather than their political affiliation – was shocking.

51
Ex. A.
52
“The Goldwater Rule is a statement of ethics first issued by the American Psychiatric Association
in 1973 restraining psychiatrists from speculating about the mental state of public figures.”
Psychology Today, https://www.psychologytoday.com/us/basics/goldwater-rule.

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It must not be.

The Village has a Board of Trustees eager to make changes to business as usual in
Maywood and a community that needs their commitment to what is best for the Village.
As one Trustee simply stated: “This is embarrassing.” The path forward is not blaming one
another for past misdeeds or getting the last, painful word in at a Board meeting. The path
forward is one wherein the Trustees listen to one another, the Village employees and the
Village residents they serve.
There are six Trustees and a Mayor in Maywood, each of whom brings a great deal
to the role. The Maywood Board is composed entirely of people of color – making it unlike
most other Boards. There is room for all of the Trustees and the Mayor to succeed in
making the Village of Maywood better. It is axiomatic that to work together we must listen
to one another. Listening does not involve hearing what the other has to say and then
explaining one’s own position. Each and every Trustee as well as the Mayor can and should
be a part of the Village of Maywood’s success. That means that the Mayor must engage
his colleagues in the first instance – it is not enough to simply tell the Trustees what he
plans to do next. He must get their buy-in and their ideas before he moves forward with his
agenda.
So, who then deserves the blame for this? Ultimately, the Mayor and the Board of
Trustees. The Mayor pushed through his preferred candidate and failed to utilize the
appropriate procedure. Although the Village Manager previously served as the Mayor of
Kankakee, for which she deserves to be congratulated, she barely met the qualifications for
her current role. Had the Mayor utilized the appropriate procedure – a competitive national
search with multiple candidates for the Board to consider – it is very likely that we would
not find ourselves where we are now. Little surprise then that the Village Manager was not
the right candidate for the job – she was the only candidate offered. After it became clear
that the relationship was unworkable, the Mayor’s political opponents reveled in his failure
while his allies jumped to his defense.
Trustee Reyes-Plummer alone voted based on her conscience, not her political
party. Now everyone must do so. Each and every Trustee must do what they believe to be
in the best interest of Maywood, not dictated by their political affiliation. In so doing the
Village of Maywood can become an example of politics at its very best.

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RECOMMENDATIONS
• Terminate the Village Manager’s employment, but also do so with dignity.
Terminate her employment without cause and offer her the severance provided for
in her contract. Utilize the attached release and waiver claims that is included with
her contract.
• Notify the community that the Village Manager is no longer with the Village and
thank her for her service.
• Begin a national search for a new village manager and place a temporary village
manager in the role during the search.
• Each Trustee must vote based on matters based on their own assessment of how
their vote will impact the Village rather than based on their political affiliation.
• End the prohibition on Village employees speaking to elected Village officials.
• Be respectful of others time.
• Revise and update the Village of Maywood’s Personnel Manual consistent with
Chapter 35 of the Maywood Municipal Code. 53
• Establish the Commission on Community Relations as provided for in Chapter 34
of the Maywood Municipal Code and adopt rules and procedures for processing
complaints against the Village, any department of the Village, or any Village
official or employee.54

53
A copy of Chapter 35 is attached hereto and incorporated herein as Exhibit R.
54
A copy of Chapter 34 is attached hereto and incorporated herein as Exhibit S.

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