A South Carolina firefighter has filed suit against the St. John’s Fire District and Fire Chief Ryan Kunitzer, alleging race discrimination and retaliation arising out of the discovery of a noose tied around the neck of a dark-skinned CPR training mannequin in his fire station.

Randy Brown filed suit in U.S. District Court for the District of South Carolina on September 23, 2026. Brown, who is African American, has been employed by the district since 2008. The St. John’s Fire District provides fire, rescue and EMS services to Johns Island, Wadmalaw Island, Kiawah Island and Seabrook Island in Charleston County.

According to the complaint:

• On September 12, 2025, Plaintiff discovered, inside his assigned District fire station, a noose tied around the neck of a dark-skinned cardiopulmonary resuscitation (“CPR”) training mannequin.
• The CPR mannequin is District property maintained at the station for the training of District personnel. Upon information and belief, the area of the station in which the mannequin was kept is accessible to District personnel and is not open to the general public.
• The noose was discovered immediately after another District crew had manned Plaintiff’s station while Plaintiff’s crew was out of the facility. The District has acknowledged this sequence of events in writing.
• Plaintiff identified members of that crew as the suspected source of the conduct.
• A noose tied around the neck of a dark-skinned human figure is an unmistakable depiction of the lynching of a Black person. Displayed inside a fire station in which Plaintiff is, upon information and belief, one of very few Black firefighters, it communicated a racial threat directed at Plaintiff and at the District’s other African American personnel.
• The display was unwelcome to Plaintiff and was motivated by race.
• Plaintiff immediately reported the noose to his Captain, Jered Michael, and to Battalion Chief Nate Adams, and provided a statement in connection with the District’s inquiry.
• Plaintiff specifically asked the Fire Chief to issue a department-wide communication acknowledging what had happened and making clear that such behavior is unacceptable.
• Plaintiff did not seek the termination of any employee. The District has acknowledged in writing that Plaintiff “did not want anyone to lose their job but wanted an apology.”
• The District never issued the department-wide acknowledgment Plaintiff requested, and no communication was made to the District’s workforce to address the seriousness of the noose or to reassure Plaintiff or others that steps were being taken to prevent a recurrence.
• The District conducted internal inquiries, which did not identify the person responsible for the noose.
• The District then retained outside counsel to interview District employees. That effort also did not identify the person responsible.
• The District then engaged the Charleston County Sheriff’s Office to conduct polygraph examinations of members of the crew that Plaintiff had identified as the suspected source of the conduct. By the District’s own account, the results of those examinations were “inconclusive.”
• Upon information and belief, the polygraph examination of firefighter Joseph Crawford (“Crawford”), a member of the crew Plaintiff identified, returned an inconclusive result.
• Upon information and belief, the District did not pursue that open investigative lead.
• On March 17, 2026, Plaintiff, through counsel, notified Chief Kunitzer in writing that Plaintiff was represented in connection with the investigation, requested that all communications regarding the matter be directed to counsel, and demanded that the District preserve all documents, electronically stored information, photographs, reports, and other materials related to the matter.
• On May 4, 2026, the District’s general counsel responded that the Charleston County Sheriff’s Department had requested to conduct “a polygraph and interview” of Plaintiff; asserted that cooperation was “mandatory for all employees, including Mr. Brown”; demanded three dates before June 1, 2026 on which Plaintiff would be available; and warned that if dates were not provided by May 15, 2026, the District would “proceed with scheduling directly with Mr. Brown.”
• The May 4, 2026 letter further described Plaintiff as “the only employee involved in any manner in the investigation who has not already complied with this requirement,” and stated that the District “reserves the right to communicate directly with Mr. Brown.”
• Upon information and belief, the District’s characterization of Plaintiff’s submission to a police polygraph as “mandatory” was intended to convey, and did convey, that Plaintiff’s refusal would be treated as a failure to comply with a job requirement.
• On May 15, 2026, Plaintiff’s counsel asked the District to identify the authority on which it relied for the position that Plaintiff’s submission to a polygraph examination was mandatory.
• On June 2, 2026, the District’s outside employment counsel responded. The only authority cited was 29 U.S.C. § 2006(a), which exempts governmental employers from the general prohibition on workplace polygraph testing in the Employee Polygraph Protection Act.
• The June 2, 2026 letter asserted that Plaintiff was “not being subjected to any questioning or measures that have not been imposed on other witnesses.” But Plaintiff was not a witness to the placement of the noose. He was its target and the complainant who reported it.
• The June 2, 2026 letter offered to issue Plaintiff a written Garrity warning — a protection afforded to public employees whose statements may expose them to criminal liability —before the polygraph, confirming that the District was prepared to examine Plaintiff in the manner of a suspect.
• Upon information and belief, the District has never before required a complainant of workplace harassment to submit to a law-enforcement polygraph examination as a condition of the District’s investigation of that complaint.
• Upon information and belief, no written policy of the District requires any employee, much less a complainant, to submit to a polygraph examination.
• The June 2, 2026 letter set a deadline of Monday, June 8, 2026, and stated that if the District did not hear from counsel by that date, the District would “move forward as it deems appropriate.”
• Plaintiff declined to submit to a police polygraph examination as the victim of the harassment, while remaining willing to cooperate fully with a good-faith investigation into the misconduct he had reported.
• On June 18, 2026, Plaintiff signed and presented his Charge to the EEOC, alleging that the District had discriminated against him because of his race in violation of Title VII.
• The Charge expressly identified the Fire Chief’s failure to issue a department-wide communication acknowledging the noose as part of the discrimination Plaintiff alleged.
• On June 26, 2026 — the very next day — Chief Kunitzer signed and sent a letter addressed to Plaintiff personally, rather than to his counsel, closing the District’s investigation (the “Closure Letter”).
• Upon information and belief, the Closure Letter was the first written communication regarding the investigation that Chief Kunitzer directed to Plaintiff personally after
• Plaintiff’s counsel requested, on March 17, 2026, that all such communications be directed to counsel.
• The Closure Letter told Plaintiff, “You have declined to cooperate with that effort,” and announced: “Given that you have declined to cooperate with the polygraph efforts, we believe that all reasonable efforts to investigate and identify the culprit have been exhausted. Accordingly, we will close the matter now . . . .”
• The Closure Letter conditioned any further investigation on Plaintiff’s submission to the police polygraph: “If you change your mind about cooperating with the polygraph
• examination, please let us know and we will arrange that.”
• The Closure Letter further stated that “other employees were not permitted to decline” the polygraph, confirming that the District treated submission to a police polygraph as a compulsory condition of employment.
• The Closure Letter did not mention the unresolved inconclusive examination of a member of the suspected crew, and did not address Plaintiff’s standing request for a department-wide acknowledgment that the conduct had occurred and would not be tolerated.
• The timing of the Closure Letter was not a coincidence. The District allowed its own June 8, 2026 deadline to pass without closing the investigation. It closed the investigation only after, and within one day of, receiving notice that Plaintiff had taken his complaint of race discrimination to the EEOC.
• By closing its investigation the day after receiving that notice, and by attributing the closure to Plaintiff’s supposed failure to cooperate, the District and Chief Kunitzer sought to create a written record shifting responsibility for the unremedied noose onto Plaintiff, in anticipation of the litigation the Notice authorized.
• The District’s and Chief Kunitzer’s conduct in closing the investigation would dissuade a reasonable employee from making or supporting a charge of discrimination.

Brown alleges the timing of the closure amounted to retaliation for his EEOC complaint. He contends the district had allowed the June 8 deadline concerning the polygraph to pass without closing the investigation, but closed it one day after receiving notice of his EEOC charge.

The complaint also makes allegations concerning Crawford. Brown claims that in May 2026, Crawford, then serving as a senior engineer, conducted a training evolution involving a female firefighter during which she suffered a head injury. The complaint alleges Crawford declined to assist her and later refused to prepare an incident report, reportedly stating words to the effect of, “I don’t do incident reports for DEI hires.” Brown alleges Crawford was not disciplined and remained in a senior position with training responsibilities.

The lawsuit asserts four counts: a race-based hostile work environment and retaliation against the St. John’s Fire District under Title VII of the Civil Rights Act of 1964; a violation of his Equal Protection rights actionable through 42 U.S.C. § 1983; and a Section 1983 equal-protection claim against the chief.

Brown is seeking compensatory damages and injunctive relief against the district, as well as punitive damages against Fire Chief Kunitzer individually. Among the injunctive relief sought is an order requiring the district to acknowledge the noose incident to its members, adopt a written policy addressing racial harassment and retaliation, reopen the investigation, and remove references characterizing Brown as having failed to cooperate.