A notorious Ohio speed trap town forced a police lieutenant out of his job for blowing the whistle on its ticket quota practices. The problem for the city of Independence is that Lieutenant Leonard Mazzola, a 23 year veteran on the force, may have had nothing to do with leaks to the media.

"Though Lieutenant Mazzola did not actually tip the press to the quotas, doing so was constitutionally protected conduct," Mazzola's attorney, Ashlie Case Sletvold, wrote in a legal brief filed Monday. "Defendants had no right to target him or strip him of his distinguished career in public service in retaliation for their embarrassment at someone having a light shined on the effort to raise revenue in Independence by targeting motorists."

Mazzola is now suing Mayor Anthony Togliatti, Police Chief Michael Kilbane, and Law Director Gregory O'Brien in federal court for violating his constitutional rights. His suit includes new evidence that the mayor pressured the police chief after seeing ticket revenue plunge at the beginning of last year. According to the suit, the chief ordered Lieutenant Mazzola to "get this turned around" by imposing a ticket quota in August 2018. The order from above had the effect of increasing citations by 27 percent, but this was not enough to satisfy the chief who wanted to see the numbers reach 3000 tickets annually -- ten per month per officer.

"To reiterate, this is not a quota, it is a performance standard fundamental to effective policing," Chief Kilbane wrote in a September 2018 memo.

Mazzola said he was ordered to discipline an officer who failed to issue the requisite number of citations. He followed through under duress, and the reprimanded officer filed a grievance. Three days later, WJW news broke the story about the the ticket quota. The story included copies of internal documents and other direct evidence.

"Defendant Kilbane was interviewed," Sletvold wrote. "He looked silly adamantly insisting that officers do not face quotas despite the fact that his own internal emails and orders show that they do."

In a February 27, 2019 email to the chief, Lieutenant Mazzola objected to the quotas, saying what was being required was illegal. Minutes after the message was sent, the chief hired an outside investigation of Mazzola as the potential media leaker, the lawsuit alleges.

"A public employee cannot be disciplined for sharing a public record with the public," Sletvold wrote. "A public employee cannot be disciplined for revealing a public policy (like a traffic-ticket quota) to the public. Whoever tipped the press about the traffic-ticket quota was engaging in constitutionally protected conduct."

The chief allegedly told Lieutenant Mazzola he could either retire or be demoted to patrolman. He chose to retire in April.