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Meredith Curtis Goode,, 443-310-9946

August 16, 2021

EASTON, MD – Calling out as “outrageous,” “shameful,” and “willfully blind” Talbot County’s arguments that Black people do not have “standing” to pursue a court challenge to a monument to white supremacy on the County Courthouse lawn, the Plaintiffs seeking a court order to remove Talbot’s Confederate monument on Friday struck back strongly in a legal filing that lays bare the cruelty, pain, and anguish actually inflicted by the monument and the County’s dismissiveness toward Black people’s concerns.

“It is unfortunate,” the Plaintiffs’ filing begins, “but all too predictable” …

“that in responding to the Complaint in this case about the unlawful Confederate statue on its courthouse grounds, Defendant Talbot County presents the viewpoint of a majority white legislative body as though it were fact, while avoiding any serious effort to confront the cruelty and illegality of its conduct toward Black people. …

“In characterizing the response of Black residents to the Talbot Boys statue as merely offensive, the County ignores the unique place of Black citizens in the eyes of the law, and reveals how little it knows (or cares) about the impact that racism and the legacy of slavery in this country and in its own backyard have on its Black residents.”

The filing includes sworn statements from the Plaintiffs detailing the actual injuries they suffer from their forced encounters with the statue.

Plaintiff Kisha Petticolas, a Black attorney who has spent her entire legal career in Talbot County, first as a judicial clerk, then as the County’s first Black Assistant State’s Attorney, and since 2011 as the only Black Public Defender at Office of the Public Defender’s Easton Office, says the County is flatly wrong it its claims that the statue is merely offensive to her. In fact, she says, the personal anguish she experiences on account of the statue is like a “knife lodged in her soul.”

“To say that the statue pains me every time I walk by it is an understatement—it is a trauma I have had to endure many times weekly throughout my 15 years of practicing law in Talbot County. The statue causes a pain that cuts deeply; one that I have learned to swallow every time I walk into the courthouse. The statue has created a wound that never truly gets the chance to heal.”

Talbot County NAACP Branch President and individual Plaintiff Richard Potter strongly agrees:

“Seeing the statue over and over throughout my life has not dulled the pain of what the statue represents. In fact, it has amplified the pain I feel, the longer that the statue remains on the courthouse grounds while the world and society’s views on Confederate statues begin to change around it. It is a thorn in my side that becomes more imbedded, more painful, and more infected with the passage of time.”

Speaking on behalf of the Plaintiff NAACP, organizational and community elder Walter Weldon Black, Jr., a former President of both the Talbot NAACP Branch and the Maryland State NAACP, said:

“[T]he presence of the Talbot Boys monument is outrageous and reprehensible, as discrimination stifles people’s ambitions while it closes the doors of opportunity. When Black people are made to feel as a second-class citizen by white society, they believe they are unable to achieve, as white society will not accept them. This symbol of white supremacy at the courthouse—maintained by County edict as the highest monument at the courthouse—combines with the fact the staff at the Talbot County courthouse is almost completely white, to send a clear message to those looking for fair opportunities at the courthouse, whether be in employment, public services, or for justice through the court system, that they are unlikely to find fairness or equality of treatment there.”

The lawsuit contends that Talbot County’s homage to white supremacists and traitors to the United States and to the State of Maryland cannot remain on government property because it is not consistent with the core promise of the Fourteenth Amendment: equality to all Americans under the law.

The Maryland Office of the Public Defender, the National Association for the Advancement of Colored People, Kisha Petticolas, and Richard M. Potter are represented by attorneys Daniel W. Wolff, David Ervin, Kelly H. Hibbert, Suzanne Trivette, Tiffanie McDowell, Alexandra Barbee-Garrett, and Ashley McMahon of Crowell & Moring LLP, and Deborah A. Jeon and Tierney Peprah of the ACLU of Maryland.

Go to our website to view the response brief, other legal documents, and learn more here.