The recently released Human Rights Complaint by Captain Mike Dominick against Sheriff T.J. McDermott pulls no punches and accuses the new sheriff of doling out benefits to political supporters while punishing political opponents.

The two men at the center of the "Unlawful Retaliation" complaint are Sheriff T.J. McDermott and former Captain of Detectives, now "Captain of the Warehouse" Mike Dominick, whose complaint recounts many incidents of concern over many years at the Missoula County Sheriff's Department.

Although McDermott and Dominick take center stage, the complaint features the names of nearly a dozen sheriff's deputies and many of the names involved are on other lawsuits currently filed either in Missoula County or Lewis and Clark County. Below is an excerpt from the complaint highlighting the extensive nature of the "enemies list" accusation.

Capt. Dominick's treatment is part of McDermott's pattern, practice or policy of maintaining an "enemies list" of those who either opposed or even did not actively support McDermott's campaign for Sheriff during the primary and general elections. McDermott has in the short time since taking office subjected at least five sworn deputies to this treatment, three of whom have worked the internal affairs or professional standards function at Missoula County since 2002. Capt. Brad Giffin felt pressured to leave when they told him his position in Professional Standards would be eliminated. Undersheriff Clark, the former Capt. of Professional Standards, was demoted to patrol deputy, and stuck on the night shift. Capt. Taylor was terminated as Captain of Patrol and moved over to the newly created position of "Administrative Captain" to perform non-law enforcement functions previously handled by a civilian employee. Former Deputy Pavalone was demoted from public information officer, labeled "Brady impaired," and then fired. Capt. Dominick, despite his expertise, leadership and years of service with distinction, has been banished to Captain of the Warehouse, in a remote building behind the jail, and given a low-level, non-supervisory job best suited to an evidence technician.

The details of the complaint also claim that before Dominick was made "Captain of the Warehouse," he was given added pressure as Chief Deputy Coroner in an effort to "make an impossible work environment."

Prior to McDermott, Capt. Dominick had 12 coroners under him, and they would rotate taking coroner's calls, to give one another essential relief from work that is highly stressful. In January, Capt. Dominick was directed by McDermott, that he was to be on call for Coroner duty during his entire four day, 40 hour work week. During this time period he took every coroner call that came in between 6:00 o'clock, a.m., and 4:00 o'clock, p.m.

The complaint goes on to say that Dominick reached out to the new authorities for help saying that the added stress from the changes for the coroners was "killing him."

Another notable aspect of the complaint includes an unnamed sheriff's deputy accused of multiple sexual improprieties that Dominick thought could lead to a potential "public relations nightmare."

Dominick reportedly went to the new authorities during the transition phase advising them to keep an eye on the deputy in question, but instead of questioning others involved, McDermott reportedly went to the accused deputy and said that Dominick was "saying bad things about him." The complaints against deputy in question were apparently all "unsigned." The HR Complaint lists them as follows:

The activity of the deputy centered around complaints of improprieties with females causing this deputy's termination from two different departments, accusations of a sexual relationship with a young cadet, reports of sexual activity going on in the deputy's car outside two different local businesses, unwanted sexual advances to a county employee, and the last and most recent: having teammates hold a woman at a traffic stop because he recognized her from Facebook and wanted to meet her.

In the final paragraphs of the complaint, Dominick notes that he is the "highest paid hourly employee in the Sheriffs office," now faced with cleaning toilets and other menial tasks while the Captain of Detectives position stays empty. In a final appeal, he asks the Human Rights Bureau to investigate and "enjoin McDermott and the County of Missoula from discriminating and retaliating against others like him in the Sheriffs Office who might disagree with McDermott's politics."