Investigation Results into Sexual Harrassment and Retaliation by Camden County Commissioner Released

The investigation into sexual harassment and retaliation by a Camden County Commissioner towards an employee in the administration building is complete.

The five-page report compiled by the Law Offices of Vessell-Bridges-Murphy retained by the commission to look into the allegations appears to be good news-bad news for Commissioner Steve Dougan…the accused in the allegations.

The report concludes that a judge or jury could determine no sexual harassment can be claimed from a text or the telling of a strip club story based on either not affecting employment and because no tangible steps were taken by Dougan to affect the employee’s employment as a result.

The report, however, also concluded that it would not be difficult for a judge or jury to find retaliation and intimidation did happen when Dougan attempted efforts to move into the same office with the employee and because the employee’s supervisor was given two disciplinary write-ups for alleged poor performance.

Full report:

To: Camden County Commissioners
From: Attorney Jack Fleming, Vessell Bridges Murphy Law Offices
Date: March 19, 2026
RE: Sexual Harassment and Retaliation Investigation Report

Introduction

On March 2, 2026, the Camden County Commissioners and I entered into an agreement in which the Commission retained me (attorney Jack Fleming) to conduct an investigation into a Commission employee’s1 complaint of sexual harassment and retaliation. The complaint was brought to the Commission’s attention on February 24, 2026, during a closed session. The complaint was made against a current Camden County Commissioner (the “accused Commissioner”).

As part of my investigation, I was provided the complaint of sexual harassment and retaliation, Camden County’s employee handbook and other policies, and various other documents and communications related to the complaint. Also, on March 7th, 10th,
and 11th, I interviewed all Commissioners and Commission employees in-person to discuss the sexual harassment and retaliation complaint and surrounding circumstances.

Finally, I will not identify any Commission employee by name in this Report. I want to protect all Commission employees that I interviewed as part of my investigation. The Commission employees all expressed legitimate and credible concerns of retaliation, and
I believe that identifying the Commission employees by name, along with the contents of my interviews with them, would only add fuel to what was described by them as a tense and toxic work environment. As I stressed to everyone interviewed, and as I will stress again now, no person that participated in the investigation should be retaliated against.

Background
On December 19, 2025, the accused Commissioner sent a text message to the personal cell phone of Complainant. The text message – in which the accused Commissioner was attempting to set up the Complainant on a date with one of his friends – states: “…I’ve heard from a few lady’s he’s been with he has stamina. TMI I could have
been lied to also.” (Crying face and laughing crying face emojis). Complainant and the accused Commissioner had never talked about Complainant’s dating life and Complainant had never asked the accused Commissioner to set her up on a date. Then, sometime in mid to late January 2026, the accused Commissioner told Complainant and The Commission employee that submitted the sexual harassment and retaliation complaint to the Camden County Human Resources Department will be known as “Complainant” in this Report to protect that person’s identity.

another Commission employee a story involving a strip club and a stripper with large breasts. Like the text message, this story was one which a judge or jury would very likely find to be highly inappropriate, especially coming from an elected official (and arguably a supervisor of Complainant) in a workplace setting. The Complainant reported the sexually suggestive text message and story to her supervisor in late January 2026. Another Commission employee reported similar concerns about the accused Commissioner to Complainant’s supervisor around that same time.

On February 2, 2026, the accused Commissioner was counseled regarding what he said to female Commission employees, including Complainant. The informal counseling session was mainly handled by another Commissioner. The Complainant’s supervisor also participated in the counseling session (in a lesser role). Based on what was revealed to the accused Commissioner during the February 2nd counseling session, the accused Commissioner knew that Complainant had raised concerns to her supervisor regarding potential sexual harassment.

After the February 2nd counseling session, the accused Commissioner began what could be perceived as a campaign of intimidation, hostility, and retaliation against the Complainant and her supervisor. Multiple attempts were made by the accused
Commissioner to drum up claims of poor work performance and insubordination against Complainant’s supervisor. A judge or jury would likely find that the only logical explanation for the targeting of the legal department (Complainant and her supervisor) is that the
accused Commissioner was attempting to intimidate and retaliate against the Complainant and her supervisor for their actions related to their protected activity (making sexual harassment complaints and addressing them on February 2nd).

Complainant spoke with Camden County Human Resources on February 19th regarding her concerns of retaliation by the accused Commissioner (as against the legal department). Another meeting between Complainant and HR was held on February 24th, during which Complainant reiterated her concerns of retaliation. Also, during the February 24th meeting, Complainant disclosed the text message that was sent by the accused Commissioner and the strip club story told to Complainant. Immediately after the February
24th meeting between Complainant and HR, Complainant sent HR an official written complaint of sexual harassment and retaliation (and supporting documentation). Later that day (February 24th), Camden County HR advised the Commissioners during a closed
session that a sexual harassment and retaliation complaint had been made against the accused Commissioner. The Complainant and her supervisor moved offices a day later, so that the Complainant and the accused Commissioner would be separated.

Importantly, on February 24th, Complainant’s supervisor was given a disciplinary write up – for alleged poor work performance that occurred (or was only first mentioned) after the February 2nd counseling session. Complainant’s supervisor was then given a
second disciplinary write-up a short time later for alleged insubordination during the February 24th closed session. Complainant’s supervisor had never received any discipline
before these two write ups. Multiple persons interviewed stated that the accused Commissioner had mentioned a “three strike” and then termination discipline policy. It is my understanding that if the Complainant’s supervisor was terminated, Complainant’s job
status would be in limbo because she could now be replaced by a new supervisor or terminated by a majority vote of the Commissioners. Complainant’s fear that the accused Commissioner was paving the way for her termination was legitimate and credible. Also,
the rationale that the disciplinary write ups against Complainant’s supervisor were for legitimate work performance reasons would likely draw great scrutiny from a judge or jury, as they were brought after the February 2nd counseling session. And, after the February
24th closed session, the accused Commissioner asked another Commissioner to identify the boss of Complainant and her supervisor. A judge or jury would likely view this question by the accused Commissioner as trying to learn how and who could get Complainant and her supervisor fired or reprimanded.

Next, the accused Commissioner – during his interview as part of this investigation – told me that he wanted to move to the same office as the Complainant and her supervisor while the investigation was ongoing. Although the accused Commissioner identified other motivations for wanting to move offices, I do not believe that a judge or jury would find them credible. Any outside observer would see this as an attempt to intimidate and retaliate against Complainant and her supervisor during the ongoing investigation.

Finally, I have legitimate concerns that the accused Commissioner attempted to undermine my investigation by intimidating – and possibly influencing – a Commission employee that was interviewed. On Friday, March 6th, during a short break in an interview with a Commission employee, the accused Commissioner made a point to introduce himself to me and explicitly asked if I was going to be interviewing a specific Commission employee. A few days later, mere minutes after I began my interview with that specific Commission employee, the accused Commissioner called the Commission Office with an urgent message for me to call him immediately. I do not find that to be a coincidence.

Conclusion

Here, a judge or jury may find that the accused Commissioner did not sexual harass Complainant, as defined by Missouri law. The Complainant is a member of a protected class (she is a female); she was subjected to unwelcome sexual harassment (the December 19, 2025, text message and January 2026 strip club story); and
Complainant’s gender was a motivating factor in the harassment. However, a judge or jury could find that the text message and strip club story did not affect a term, condition, or privilege of Complainant’s employment. No tangible employment action, such as hiring and firing, promotion and demotion, undesirable reassignment, or compensation decisions were taken by the accused Commissioner against Complainant as a result of the text message and strip club story. See M.W. by & though K.W. v. Six Flags St. Louis, LLC, 605 S.W.3d 400, 411 (Mo. Ct. App. 2020). While the accused Commissioner’s conduct would almost certainly be found by a judge or jury to be highly inappropriate and of a sexual nature, “under Missouri and federal precedent examining hostile work
environment claims under the MHRA [Missouri Human Rights Act], some inappropriate behavior objectively does not rise to the level of actionable harassment as a matter of law.” Id. I believe a fact finder could conclude that is the case here – the accused
Commissioner’s text message and strip club story do not objectively rise to the level of actionable harassment as a matter of law. Also, the accused Commissioner did not subject Complainant to any unwelcome text messages or stories after the February 2nd
counseling session.

The sexual harassment/hostile work environment claim is a very close call, and a judge or jury could very well find that the accused Commissioner did sexually harass Complainant. The accused Commissioner is arguably a supervisor of Complainant – and
he is an elected official – so his conduct does have great power to alter the workplace environment. But a judge or jury would more likely conclude that Complainant’s sexual harassment complaint and her supervisor’s counseling of the accused Commissioner on
February 2nd, and the retaliation that ensued, caused the hostile and abusive work environment. As an aside, allegations and insinuations during my investigation that the Complainant did not feel that the accused Commissioner’s actions  were “unwelcome” were not credible. Finally, the accused Commissioner’s lack of remorse and
understanding of the severity of his conduct (in sending the highly inappropriate text message and telling the strip club story to a female subordinate) was troubling.

The accused Commissioner’s actions after February 2nd were targeted at the legal department (Complainant and her supervisor), and a judge or jury would likely find the accused Commissioner’s actions after February 2nd constitute retaliation under Missouri
law because the accused Commissioner’s actions created a hostile and abusive work environment. After the February 2nd counseling session, the accused Commissioner made Complainant legitimately fear for her job because of alleged performance issues related to the legal department that were only brought up – and drummed up – after the February 2nd counseling session. A reasonable and objective person would have felt that the accused Commissioner’s conduct created an intimidating and hostile work environment for Complainant and her supervisor. A fact finder would likely conclude that the accused Commissioner was laying the groundwork to fire the Complainant’s supervisor and then Complainant for pretextual reasons. Although the accused Commissioner mainly had issues with Complainant’s supervisor’s work performance, his ire and hostility were taken out on Complainant through repeated and abusive requests for documents and by rarely speaking to or addressing work issues with Complainant directly.

Also, the accused Commissioner took the overt step of issuing the Complainant’s supervisor two undeserved disciplinary write ups (after the February 2nd counseling session). As previously stated, the accused Commissioner had mentioned a “three strike” and then termination discipline policy, so a judge or jury would likely conclude that the accused Commissioner was laying the groundwork for terminating Complainant’s supervisor. And, if Complainant’s supervisor was terminated, the accused Commissioner would have an easier time getting the Complainant terminated or forcing her out of her position because she could now be terminated by a vote of two of the three Commissioners or replaced by a new supervisor. While neither Complainant nor her supervisor were ultimately terminated, and Complainant’s supervisor was the only one disciplined, a judge or jury would still likely conclude that the accused Commissioner
retaliated against Complainant by creating a hostile and abusive work environment in which Complainant legitimately feared for her job.

It would not be difficult for a judge or jury to find that retaliation occurred here. Complainant made protected complaints of sexual harassment to her supervisor in late January 2026 (and later to HR on February 19th and 24th). On February 2nd, another
Commissioner and Complainant’s supervisor counseled the accused Commissioner regarding his inappropriate workplace comments to female employees (including Complainant). By all accounts, the accused Commissioner knew that Complainant had made the sexual harassment complaints that were part of the reason the accused
Commissioner was counseled on February 2nd.

A jury would likely conclude that after the February 2nd counseling session, the accused Commissioner began manufacturing performance issues with the legal department in an attempt to get Complainant and her supervisor terminated. Even during this investigation, the accused Commissioner attempted to move into the office building that Complainant and her supervisor had just moved into in order to separate themselves from the accused Commissioner. This overt and blatant intimidation tactic – which would have only intensified the already hostile and abusive work environment – lends credence to the determination that the accused Commissioner’s actions after February 2nd were in retaliation for Complainant and her supervisor’s protected activity (in making and
reporting/addressing complaints of sexual harassment).

In sum, a judge or jury would likely find by a preponderance of the evidence (more probable than not) that the accused Commissioner’s actions against the legal department after February 2nd constitute retaliation and were a pretext for attempting to get Complainant’s supervisor and then Complainant fired. A judge or jury would likely
conclude that there was a causal relationship between Complainant’s complaint of sexual harassment and her supervisor’s role in counseling the accused Commissioner on February 2nd, as well as the accused Commissioner’s actions towards Complainant and
her supervisor thereafter. Finally, a judge or jury would likely find that Complainant’s sexual harassment complaint and her supervisor addressing her complaints were the motivating factor in the accused Commissioner’s targeting and intimidation of the legal department, which resulted in a hostile, intimidating, and abusive work environment.

In conclusion, while it is a very close call whether a judge or jury would ultimately conclude that the text message and strip club story constitute actionable sexual harassment under Missouri law, the retaliation claim is not a close call. A judge or jury would likely find that the accused Commissioner retaliated against Complainant and her supervisor by creating an abusive, intimidating, and hostile work environment because Complainant reported the sexual harassment and her supervisor addressed it.

Sincerely,
Jack Fleming
Jack Fleming
Jack.Fleming@VBMLaw.com
JPF/