IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TEXAS

UNITED STATES OF AMERICA

                                 Plaintiff

                                                                CIVIL ACTION NO.
                                         v.

CAMP RIVERVIEW, INC.
d/b/a CAMP RIVERVIEW,
JIMMY MEYER, individually,
and SUZANNE MEYER,
individually

                                 Defendants

______________________________

PLAINTIFF UNITED STATES' COMPLAINT FOR INJUNCTIVE RELIEF

The United States of America alleges that:

1. This action is brought by the Attorney General on behalf of the United States to enforce Title II of the Civil Rights Act of 1964 (the Public Accommodations Act), 42 U.S.C. § 2000a, et seq.

Jurisdiction

2. This Court has jurisdiction over this action pursuant to 42 U.S.C. §§ 2000a(a), 2000a-2, and 2000a-5(a) and 28 U.S.C. § 1345.

3. Venue is proper in the Western District of Texas because the acts at issue occurred in this District, and the Defendants do business here.

The Parties

4. Defendant Camp Riverview, Inc. is a Texas corporation. Camp Riverview, Inc., operates in Concan, Texas, in the Western District of Texas.

5. Defendant Jimmy Meyer is the President, a Director and co-owner of Camp Riverview, Inc.

6. Defendant Suzanne Meyer is a Director and co-owner of Camp Riverview, Inc.

7. Camp Riverview is a campground with approximately 30 spaces for overnight camping as well as several cabins and shelters. The campground is located at HCR 70, Box 471, in Concan, Texas.

8. Camp Riverview is a place of public accommodation within the meaning of 42 U.S.C. § 2000a(b)(1).

9. The operation of Camp Riverview affects commerce within the meaning of 42 U.S.C. § 2000a(c)(1).

10. Upon information and belief, both Jimmy Meyer and Suzanne Meyer currently reside in Concan, Texas, on the Camp Riverview property.

Title II Violations

11. Defendants, through their own actions, or the actions of their employees or agents, have implemented a policy and practice of denying to Hispanic individuals, on account of national origin and/or color, the full and equal enjoyment of Defendants' goods, services, facilities, privileges, advantages, and accommodations, on the same basis as they make them available to white persons. Defendants and their agents have carried out this policy and practice by, among other things:

1. Evicting Hispanic individuals from the campground property;

2. Harassing Hispanic guests who are staying at Camp Riverview;

3. Enforcing campground rules in a discriminatory manner on the basis of national origin (i.e., Hispanic);

4. Denying Hispanic individuals accommodations; and

5. Intimidating, threatening, coercing, or attempting to intimidate, threaten, or coerce persons with the purpose of interfering with their rights to equal enjoyment of the goods, services, facilities, privileges, advantages and accommodations offered to patrons of the campground.

12. Defendants' conduct constitutes a pattern or practice of resistance to the full and equal enjoyment by Hispanic individuals of rights secured by 42 U.S.C. § 2000a, et seq., and the pattern or practice is of such a nature and is intended to deny the full exercise of such rights. Unless restrained by Order of this Court, Defendants will continue to refuse to provide Hispanic individuals with the full and equal enjoyment of rights secured to them by 42 U.S.C. § 2000a, et seq.

Prayer for Relief

WHEREFORE, the United States requests that the Court enter an Order:

1. Declaring that the discriminatory practices and policies of the Defendants violate Title II of the Civil Rights Act of 1964, 42 U.S.C. § 2000a, et seq.;

2. Enjoining Defendants, their employees, agents, and successors, and all other persons in active concert or participation with them, from engaging in any act or practice which, on the basis of national origin and/or color, denies or abridges any rights secured by Title II of the Civil Rights Act of 1964, 42 U.S.C. § 2000a, et seq.;

3. Enjoining Defendants, their employees, agents, successors, and all other persons in active concert or participation with them, from: (a) intimidating, threatening, coercing, and attempting to intimidate, threaten, or coerce persons with the purpose of interfering with their rights or privileges secured by 42 U.S.C. § 2000a, in violation of 42 U.S.C. § 2000a-2; and/or (2) punishing or attempting to punish persons for exercising or attempting to exercise any right or privilege secured by 42 U.S.C. § 2000a, in violation of 42 U.S.C. § 2000a-2; and

4. Requiring Defendants, their employees, agents, and successors, and all other persons in active concert or participation with any of them, to take such affirmative steps as may be necessary to remedy the past unlawful conduct.

The United States further prays for such additional relief as the interests of justice may require, together with the costs and disbursement of this action.

JOHN ASHCROFT Attorney General

JOHNNY SUTTON United States Attorney Western District of Texas ____________________________ SUSAN BIGGS Texas State Bar No. 92312500 Assistant U.S. Attorney Office of the U.S. Attorney for the Western District of Texas 601 NW Loop 410 Suite 600 San Antonio, Texas 78216

____________________________ RALPH BOYD JR. Assistant Attorney General Civil Rights Division ____________________________ JOAN A. MAGAGNA Chief Housing and Civil Enforcement Section Civil Rights Division (210) 384-7351 (210) 384-7312 (fax) ____________________________ JEANINE M. WORDEN Deputy Chief ELISE S. SHORE Attorney Housing and Civil Enforcement Section - G St. Civil Rights Division U.S. Department of Justice 950 Pennsylvania Ave, N.W. Washington, D.C. 20530 (202) 514-4701 (202) 514-1116 (fax)

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Document Filed: October 21, 2002