Amended complaint 2

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IV. CLAIMS A. CIVIL RIGHTS VIOLATIONS Overview 31.

Since at least 2006, the City of Racine, its Mayor, alderpersons and municipal

departments have waged war on minority-owned taverns in downtown Racine sthat cater to minority clientele. At the same time, they have turned a blind eye to the infractions committed by white-owned tavern owners and their mostly white patrons, actively supporting and protecting them instead of policing them in the manner they do minority-owned taverns. 32.

The City of Racine, its Mayors, members of the Licensing Committee and the

Common Council systematically imposed heightened burdens on minority-owned bars through administrative agencies, the Police Department, and by other means, making it difficult for them to obtain or maintain a liquor license. 33.

Since 2006, minority bar owners’ applications for liquor licenses have been

disproportionately denied by the Licensing Committee, when compared with white bar owners’ applications, because the minority owners’ liquor licenses were, ostensibly, contrary to the health, safety, or welfare of the public or any regulation, law, or ordinance applicable to the liquor licenses. In denying minority bar owners’ applications, the Licensing Committee also often cited to the “fragility” of the neighborhood or the “oversaturation” of liquor licenses in the area. 34.

Despite the fact that similar, if not more, police calls and violent acts took place at

white-owned establishments, white bar owners have rarely been denied a requested liquor license since 2006.

10 Case 2:14-cv-00208-JPS Filed 08/21/14 Page 10 of 119 Document 62


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