MIDDLETON — Police Chief William Sampson is suing the town and Town Administrator Justin Sultzbach, saying he has been subject to discriminatory and retaliatory conduct and is being forced out of his job.
The lawsuit was filed in Essex County Superior Court on Sept. 2. Sampson is suing the town on counts of Disability Discrimination, Retaliation, Breach of Contract, and Breach of the Implied Covenant of Good Faith and Fair Dealing; Sultzbach is being sued on a count of Interference and Aiding and Abetting; while both are in the suit for Declaratory Judgment in the matter.
Sampson is currently on Injured-On-Duty leave and has served as Middleton’s police Chief since 2021.
The suit alleges that last September, six days after he returned from his first approved Injured-On-Duty leave, Sultzbach gave him the ultimatum to resign immediately or accept a disciplinary Performance Improvement Plan (PIP) that would see Sultzbach decide “through a subjective scoring system whether to seek Sampson’s termination.”
“When Sampson objected through counsel that the PIP and related treatment were discriminatory and retaliatory, defendants escalated the pressure,” Sampson’s attorney wrote in the lawsuit.
The core issues of the suit began in 2025, not long after Sultzbach had given Sampson a 66.7% on a performance review that May. Despite that lower mark, Sampson argued Sultzbach did not indicate in his rating that his job was in jeopardy, nor that discipline or a PIP was needed.
Then in June of that year, Sampson injured his dominant right arm during mandatory firearms qualification and was diagnosed with lateral epicondylitis, a condition also known as Tennis Elbow that causes pain in the elbow and results from overuse of an arm.
The chief was approved for Injured-On-Duty leave the next month and returned to work medically cleared without restriction on Aug. 29, 2025. Six days later, in a meeting organized by Sultzbach, the town administrator told him he must resign immediately or accept a disciplinary PIP that must be completed to Sultzbach’s personal satisfaction, according to the lawsuit.
Sampson said Sultzbach told him he must earn at least a four out of five points in each category of a biweekly scoring system in order to pass, and that the Town Administrator said he did not believe in awarding a five in any category, according to the lawsuit.
“By requiring a four while categorically withholding a five, Sultzbach left himself nearly complete subjective control over whether Sampson passed or faced termination,” the lawsuit states.
The PIP also significantly restricted Sampson’s authority and required more approval for actions on the chief’s part, including his ability to conduct training sessions.
“The PIP’s standards shifted as Sampson attempted to comply,” according to the lawsuit. “After criticizing him for communicating too little, Sultzbach criticized him for communicating too much and characterized his compliance as malicious. Sultzbach also gave Sampson only a three for officer appreciation and refused to credit recognition efforts because Sampson had not first reported each one to him.”
An attorney representing Sampson sent a letter to Sultzbach and the Select Board chair on Oct. 8, 2025, that objected to the PIP, calling the town’s treatment of the Chief discriminatory under the law.
That fall, Sultzbach gave Sampson passing scores of four in all but one category, which he assigned a two, and claimed that sole failing score justified termination, calling their relationship “unsustainable,” according to the lawsuit. An “Expectations for Enhanced Management Oversight” memorandum was also placed in Sampson’s personnel file.
Sampson filed the first of two charges against the town with the Massachusetts Commission Against Discrimination in March of this year. He again injured his dominant arm and also his hand during mandatory firearms evaluations in June, and went back on Injured-On-Duty leave.
On Aug. 4, while Sampson was on leave and as the first MCAD charge remained pending, the Select Board voted in executive session not to renew Sampson’s three-year contract extension that was signed in May of 2024, according to the suit.
“The town thereafter informed Sampson through counsel that it intended not merely to allow the contract to expire, but to terminate him during its remaining term and separately pursue removal from his indefinite appointment as chief,” the lawsuit states.
According to the suit, the town failed to follow its own procedures regarding termination. The town also pinned the decision to terminate Sampson “at least in part, on statements Sampson supposedly made concerning renewal and an alleged understanding that he planned to relocate to Florida.”
Sampson did take part in a hiring process for a police chief position with the Port Richey City Council in Florida in February 2025. But he was not hired in the role and never told the town that he would be leaving or planned to, nor did Sultzbach know of the potential Florida job when he implemented the PIP that fall, the lawsuit argues.
Sampson filed a second MCAD charge following the Aug. 4 vote. He contends he is still fit to serve as chief and that no medical provider has found him permanently unfit for the role as a result of his injury.
In addition to a declaratory judgement that would protect procedural rights and benefits established in his contract and the town’s charter, Sampson is requesting front pay, back pay, lost benefits, contractual damages and actual damages with interest.
He is also asking for compensatory damages, including damages for emotional distress, along with punitive damages and for the defendants to cover his attorneys’ fees and legal costs in the matter.
Sultzbach declined to comment on the lawsuit, telling The Salem News this week that “By practice, the town does not comment on ongoing personnel issues.”
Contact Caroline Enos at CEnos@northofboston.com.