This Amended Complaint was filed on December 2. It adds a third cause of action for damages stemming from locking him out of his faculty apartment. A couple of quick thoughts on the complaint, without the benefit of having done any legal research on his claims:

1. He is claiming $300,000 in damages stemming from his termination. Even assuming he could prove that the dismissal breached his employment contract (and I would like to think that would be difficult/impossible), he should only be able to get damages for the last few weeks of the semester. He is going to jail in February, and therefore will be unable to fulfill his obligations under the contract beginning with next semester (I am assuming the contract requires him to teach). So most of this $300,000 claim should be gotten rid of fairly easily.

2. I don’t know anything about the COBRA law he is citing, but hopefully the College had its lawyers give some thought and research before they denied him COBRA access. As far as damages from this claim, I believe that once he is incarcerated, he gets health care through the prison system, so that might limit some of those damages, if he is entitled to anything.

3. I suspect that Massachusetts is a fairly tenant friendly state (though I have not first hand knowledge on this), so its possible that the new third count could have some merit. I know that here in DC – which is incredibly pro-tenant – colleges and universities have additional rights to self-help (e.g. changing the locks) in the dorm context not available to normal landlords. Hopefully Mass has similar protections for Williams which would be applicable to the faculty housing Moore was living in.

4. Its not clear what his basis for punitive damages is, but that is the bulk of his monetary claim, so if this can be eliminated, that would get rid most of the damages.

5. Does anyone know if he can get attorneys fees if he is proceeding pro se?

Link to Amended Complaint

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