IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ALABAMA

WESTERN DIVISION

J .G., )
Plaintiff, )
)
vs. )
) Civil Action No. ______________
J effrey Dale Eddie, Highland Park )
Baptist Church, and Loving the Shoals )
United Appeal Fund, Inc., )
)
Defendants. )


COMPLAINT


COMES NOW the Plaintiff, J .G., (Plaintiff) and for his complaint
against the Defendants, J effrey Dale Eddie, Highland Park Baptist Church,
and Loving the Shoals United Appeal Fund, Inc., states as follows:
PARTIES


1. The Plaintiff, J .G., is an adult resident and citizen of Ascension

Parrish, Louisiana.

2. The Defendant, J effery Dale Eddie, is an adult resident and
citizen of Colbert County, Alabama. J effrey Eddie was charged with thirty-
six (36) counts related to child sex abuse. On March 7, 2014, J effrey Eddie
pled guilty to 16 counts of sodomy for oral sex, 3 counts of sexual abuse of a
child under the age of 12 and one count of possession of child pornography.
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FILED
2014 Jul-22 PM 02:45
U.S. DISTRICT COURT
N.D. OF ALABAMA
Case 7:14-cv-01410-SLB Document 1 Filed 07/22/14 Page 1 of 13
J effrey Eddie was sentenced to thirty (30) years in prison.
3. The Defendant, Highland Park Baptist Church is a Southern
Baptist Church in association with the Colbert-Lauderdale Baptist
Association, the Alabama State Board of Missions and the Southern Baptist
Convention. It is located in Colbert County, Alabama. Defendant J effrey
Eddie was employed by Highland Park Baptist Church from 1998 until 2014
and held the position of Administrative/Childrens Pastor.
4. The Defendant Loving the Shoals United Appeal Fund, Inc., is
a corporation formed in Colbert County, Alabama. The purported nature of the
business is to, glorify God by raising funds to support the benevolence
activities of The Highland Park Baptist Church of Muscle Shoals, Alabama.
J effrey Eddie is listed as an incorporator, director and registered agent of this
Defendant.

FACTUAL BACKGROUND

5. Beginning in approximately 2001, Defendant J effrey Eddie
attempted to, and did, commit sexual acts including, but not limited to, fondling
the plaintiffs testicles, physical masturbation and attempted oral sex on J .G.
who was approximately 11 years old at the time.

6. Defendant J effrey Eddie continued to perpetrate these acts on
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J .G. until approximately November 2013.

7. Those acts of sexual abuse took place in various locations at
Highland Park Baptist Church, including J effrey Eddies office and a storage
closet attached to J effrey Eddies closet. Those acts of sexual abuse also took
place on Highland Park Baptist Church sponsored trips including, but not
limited to, camp retreats at Earle Trent Assembly Camp and church sleepovers
at J effrey Eddies home. Further, the acts of sexual abuse took place while
J effrey Eddie was driving the church van shuttling youth to Highland Park
Baptist Church sponsored events.

8. At all times relevant to the acts of sexual abuse against J .G.,
J effrey Eddie was employed with Highlands Park Baptist Church as the
Administrative/Childrens Pastor.

9. At all times relevant to the acts of sexual abuse, J .G.s wellbeing
had been entrusted to Highlands Park Baptist Church by his parents.
10. Upon information and belief, Highlands Park Baptist Church
provided J effrey Eddie with little to no oversight, monitoring or supervision.
J effrey Eddies office at Highlands Park Baptist Church was isolated from all
other administrative offices. J effrey Eddie covered the only window in his office
with a bulletin board which prevented anyone from looking in his office. J effrey
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Eddie also closed the blinds on the door to his office and frequently locked his
office door while individual children were present in his office. J effrey Eddie
was given sole control over the installation and monitoring of security cameras.
Highlands Park Baptist Church provided J effrey Eddie with two cellular phones
one of which had a different carrier and separate billing record from all other
church phones. J effrey Eddies computer and phone activity were never
monitored during his fourteen year employment.

11. Upon information and belief, child pornography was stored on the
Highlands Park Baptist Church computer located in J effrey Eddies office.

12. Upon information and belief, Highlands Park Baptist Church
waited ten (10) days after a reported incident and insisted on doing its own
investigation before disclosing the sexual abuse to the police. This delay was
in violation of Alabama law which requires clergy to report suspected abuse
immediately.

13. Upon information and belief, J effrey Eddie repeatedly and
consistently sexually abused other children during his fourteen (14) year tenure
with Highlands Park Baptist Church.

14. Upon information and belief, Highlands Park Baptist Church
now provides and continues to provide J effrey Eddies full compensation to
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his wife a nonemployee. Such compensation includes J effrey Eddies full
salary, benefits and free cellular phone service.
JURISDICTION AND VENUE

15. J urisdiction is proper in this Court by virtue of 28 U.S.C.
1332, diversity of citizenship, and the amount in controversy exceeds
Seventy Five Thousand Dollars ($75,000.00) exclusive of interest and costs.
Venue is appropriate in this Court since all activities made the subject of this
action originated and occurred within this judicial district.
COUNT I
(infliction of emotional distress)


16. Defendant J effrey Eddie negligently and/or wantonly inflicted
emotional distress upon the Plaintiff when he perpetrated sexual acts on him
over a period of approximately 12 years.

17. Plaintiff was damaged as a result of the Defendants actions.

COUNT II
(invasion of privacy)


18. Defendant J effrey Eddie did negligently and/or wantonly invade
the Plaintiffs privacy when he perpetrated sexual acts on him over a period of
approximately 12 years.

19. Plaintiff was damaged as a result of the Defendants actions.
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COUNT III
(assault and battery)


20. Defendant J effrey Eddie did negligently and/or wantonly
commit assault and battery upon the Plaintiff when he perpetrated sexual acts
on him over a period of approximately 12 years.

21. Plaintiff was damaged as a result of the Defendants actions.

COUNT IV
(false imprisonment)


22. Defendant J effrey Eddie did negligently and/or wantonly falsely

imprison the Plaintiff when he perpetrated sexual acts on him over the course of

approximately 12 years.


23. Plaintiff was damaged as a result of the Defendants actions.

COUNT V
(negligence)


24. Defendant J effrey Eddie did act negligently when he perpetrated
sexual acts on the Plaintiff over the course of approximately 12 years.

25. Plaintiff was damaged as a result of the Defendants actions.

COUNT VI
(outrage)


26. Defendant J effrey Eddie committed the tort of outrage when he
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perpetrated sexual acts on the Plaintiff over the course of approximately 12
years.

27. The act of sexual abuse on a minor is utterly reprehensible and
cannot be tolerated in a civilized society.

28. Plaintiff was damaged as a result of the Defendants actions.

COUNT VII
(breach of fiduciary duty)


29. At all times relevant to the acts of sexual abuse against J .G.,
J effrey Eddie was employed with Highlands Park Baptist Church as the
Administrative/Childrens Pastor and had a position of authority and power
over J .G. as a result of his employment.

30. At all times relevant to the acts of sexual abuse against J .G.,
J effrey Eddie was acting as a spiritual counselor and was providing spiritual
guidance and instruction to J .G. As such, a fiduciary duty existed between
J effrey Eddie and J .G.

31. J effrey Eddie breached his fiduciary duty by sexually abusing J .G.

over the course of approximately 12 years.


32. Plaintiff was damaged as a result of the Defendants actions.




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COUNT VIII
(respondeat superior and/or agency)


33. At all times relevant to the acts of sexual abuse against J .G.,
J effrey Eddie was employed with Highlands Park Baptist Church as the
Administrative/Childrens Pastor and had a position of authority and power
over J .G. as a result of his employment.

34. At all times relevant to the acts of sexual abuse against J .G.,
J effrey Eddie perpetrated the sexual abuse at the physical location of Highlands
Park Baptist Church or during a church approved trips where J .G.s well-being
had been entrusted to the church.

35. J effrey Eddies conduct and contact with J .G. leading up to the
sexual abuse fell within his scope of employment with Highlands Park Baptist
Church. As such, the sexual abuse was an outgrowth and was engendered by
his employment with Highlands Park Baptist Church.

36. The significant job-created authority possessed by J effrey Eddie
enabled him to sexually abuse J .G., and other minors entrusted to the care of
Highlands Park Baptist Church.

37. Instrumentality furnished by Highlands Park Baptist Church,
such as computers and cell phones, vans and offices were used to further the
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sexual abuse of J .G. and other minors entrusted to their care.
38. The sexual abuse of J .G. by J effrey Eddie would not have occurred
but for J effrey Eddies employment by Defendant Highland Park Baptist
Church.
39. Defendant Highland Park Baptist Church knew or should have
known the J effrey Eddie posed a serious threat to the minors entrusted in their
care.
40. For the reasons stated above, Highlands Park Baptist Church is
liable under the theory of respondeat superior and/or agency for the infliction
of emotional distress, invasion of privacy, assault and battery, false
imprisonment, negligence, outrage and breach of fiduciary duty (Counts I VII)
committed by J effrey Eddie.
COUNT IX
(failure to supervise, train and hire)


41. Defendant Highlands Park Baptist Church negligently and/or
wantonly failed to supervise, train and hire its employees, including but not
limited to J effrey Eddie.

42. Defendant, Loving the Shoals United Appeal Fund, Inc., upon
information and belief, negligently and/or wantonly failed to supervise, hire
and train its employees and agents, including but not limited to J effrey Eddie.
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43. Despite being entrusted with hundreds of children, Defendant
Highlands Park Baptist Church failed to adequately train its staff regarding the
identification and reporting of child abuse and failed to adequately hire staff
that could identify and would report child abuse.

44. Defendants failed to provide oversight, monitoring and/or
supervision for J effrey Eddie - the employee entrusted with the minor
children. Defendants allowed J effrey Eddie to possess an office which was
isolated from all other administrative offices, to visually conceal all activity
which occurred in that office, to be alone with individual children in that
isolated office, and to lock the door of his office when he was alone with
those children. Defendants allowed J effrey Eddie to operate autonomously and
outside of ordinary channels.
45. Defendants negligently and/or wantonly failed to monitor the
phone history, computers and other electronic devises of its
employees, including J effrey Eddie.
46. Defendants negligently and/or wantonly failed to provide oversight

and supervision when it allowed an adult male pedophile to have one-on-one

contact and authority over J .G. and on the other children who were placed in

their care.
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47. Defendants negligently and/or wantonly failed to train their
employees to identify and report the ongoing sexual acts which were
perpetrated on J .G. and on numerous other children placed in their care.
48. Defendants negligently and/or wantonly failed to institute and/or
enforce policies which would safeguard against an adult male having
unsupervised intimate contact with the children placed in their care.

Prayer for Relief


1. The negligent, wrongful and/or wanton conduct of the Defendants
J effrey Eddie, Highlands Park Baptist Church, and Loving the Shoals United
Appeal Fund, Inc., have resulted in the following damages:
(a) The Plaintiff was caused to suffer physical injury;

(b) The Plaintiff was traumatized by the acts of sexual abuse
and was caused to suffer and continues to suffer mental
anguish;

(c) The Plaintiff was caused to be permanently injured;

(d) The Plaintiff was caused and will be caused in the future to
expend money in the nature of doctor, hospital, drug,
counseling and other medical expenses in an effort to cure
and/or assist with tolerating his injuries; and

(e) The Plaintiff was caused to be permanently unable to
pursue many of his normal and usual activities.

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WHEREFORE, PREMISES CONSIDERED, the Plaintiff seeks an
award of compensatory and punitive damages in excess of the jurisdictional
minimum of this Court, and in an amount determined by a jury to be fair and
reasonable based on the evidence presented in this case.
PLAINTIFF HEREBY DEMANDS A TRIAL BY STRUCK JURY



/s/ Erik S. Heninger
ERIK S. HENINGER (ASB-1189-k46h)
GAYLE L. DOUGLAS (ASB-6974-e63d)
BRANDY L. ROBERTSON (ASB-2737-d65r)
Attorneys for Plaintiff
Of Counsel:

HENINGER GARRISON DAVIS, LLC
2224 1
ST
Avenue North
Post Office Box 11310 (35202)
Birmingham, Alabama 35203
205.326.3336 (phone)
205.326.3332 (facsimile)
[email protected]
[email protected]
[email protected]









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DEFENDANTS TO BE SERVED VIA CERTIFIED MAIL:

Highland Park Baptist Church
501West 6
th
Street
Muscle Shoals, AL 35661


J effrey Dale Eddie AIS#00293645
Bibb County Correctional Facility
565 Bibb Lane
Brent, AL 35034


J effrey Dale Eddie
c/o William J . Underwood, Esquire
Post Office Box 245
Tuscumbia, AL 35674-2036


Loving the Shoals United Appeal Fund
c/o Highland Park Baptist Church
501 West 6
th
Street
Muscle Shoals, AL 35661
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