Greco Files Expanded Federal Complaint Alleging ‘Table of Success’ Patronage, Retaliation, and Municipal Liability in New York City

The Table of Success Litigation

For Immediate Release

 

Litigation Uncovers Coordinated Digital Retaliation, Credential Weaponization, and the Systemic Collapse of Municipal Ethics Oversight (2022–2026)

 

New York, New York, February 12, 2026 — Salvatore J. Greco has filed an expanded federal complaint in the United States District Court for the Eastern District of New York, Docket No. 26-cv-00808, alleging that a coordinated network of City and NYPD leadership actors retaliated against him for protected First Amendment activity, including his public anti-corruption reporting through social media and The Sal Greco Show, and for his continued prosecution of a pending federal civil-rights action in the Eastern District of New York. The suit names THE CITY OF NEW YORK, ERIC L. ADAMS, JESSICA S. TISCH, KAZ DAUGHTRY, JOHN M. CHELL, RAJUB B. BHOWMIK, ANTHONY L. HERBERT, and JOHN DOES 1–5.

The complaint alleges an escalating pattern of retaliatory conduct carried out through both formal and informal government channels, including monitoring, intimidation, reputational targeting, proxy-account amplification, employment interference, and credential/status-linked harm mechanisms. Greco alleges this was not random online friction or isolated conduct by a few individuals, but a municipal pattern known to, tolerated by, and/or ratified by final policymakers, and sustained despite repeated public notice, oversight findings, and investigative events.

At core, this case asks whether public officials may use state-linked power—openly or by proxy—to raise the cost of criticism and litigation for a citizen-journalist and federal civil-rights plaintiff whose reporting targeted command-level corruption, governance failures, and political favoritism.

Case Framing: Protected Speech, Petitioning, and Alleged Retaliation

Greco alleges he engaged in constitutionally protected activity by publicly commenting on corruption-related developments involving City Hall, mayoral agencies, public benefit corporations, and NYPD command structures, while also petitioning government through active federal litigation. The complaint pleads that this protected activity triggered coordinated retaliation intended to chill speech and interfere with litigation posture.

The pleading states that Greco’s commentary was not private gossip or purely personal dispute. It was public-interest reporting on issues of governance integrity, ethics compliance, command accountability, procurement, favoritism, and alleged selective enforcement. According to the complaint, that reporting made Greco “a thorn in the side” of powerful actors and prompted an ongoing pressure campaign designed to discredit him, intimidate participants in his media ecosystem, and deter continued scrutiny.

Greco alleges the pattern included:

  • monitoring and tracking his broadcasts and social content;

  • targeted digital hostility and reputational smearing;

  • proxy and pseudonymous account activity linked to command-level interests;

  • efforts to intimidate guests and viewers of The Sal Greco Show;

  • and selective use of administrative/credential channels with punitive downstream effects.

Named Defendants and Alleged Conduct

The complaint attributes specific categories of conduct to specific defendants, including allegations that:

  • The City of New York is alleged to bear municipal liability where policymakers had notice and failed to prevent recurrence.
  • Eric L. Adams personally and/or through emissaries engaged in conduct aimed at chilling Greco’s speech and affecting litigation dynamics during active federal proceedings.
  • Anthony L. Herbert is alleged to have participated in unsolicited online attack activity as part of the wider retaliatory campaign.
  • Jessica S. Tisch is alleged to have permitted or participated in a governance environment in which NYPD resources and command-level channels were used to monitor, target, and chill protected commentary.
  • Kaz Daughtry is alleged to have been a focal point of complaints regarding authority, conduct, and social-media-linked retaliation patterns.
  • John M. Chell is alleged to have engaged in or been linked to hostile messaging and proxy-account aggression tied to Greco’s protected speech.
  • Rajub B. Bhowmik is alleged to have repeatedly and falsely portrayed Greco as racist, and to have acted to intimidate Greco’s guests/viewers and suppress audience participation to protect City-aligned actors.

Greco alleges this conduct was cumulative, intentional, and operationally linked—functioning as a deterrent architecture rather than a series of disconnected disputes.

Handschu Framework and Political-Speech Monitoring

A central legal frame in the complaint is the long federal history of limits on NYPD investigative activity touching political expression. Greco invokes the Handschu line to emphasize that intelligence or investigatory activity directed at political speech has historically required defined predicates, documentation, and supervisory controls—not open-ended monitoring of dissent.

The complaint’s theory is that Defendants’ alleged monitoring of The Sal Greco Show, its guests, and viewers, combined with related proxy-account activity, departed from those constraints and functioned as viewpoint-driven retaliation. Greco alleges this was operationalized not as neutral law-enforcement practice but as pressure targeting a vocal critic in active federal litigation.

The lawsuit places this in constitutional terms: government may answer criticism, but may not weaponize public authority to burden protected speech and petitioning through intimidation, surveillance-style tracking, or retaliatory reputational tactics.

Chronological Corruption Commentary and Alleged Retaliatory Escalation

The complaint integrates a broad chronology of public corruption developments and alleges that Greco’s reporting on those events was followed by intensified hostility and targeting. This includes allegations tied to what Greco describes as a City Hall “Table of Success” patronage architecture; Turkish influence and campaign-finance controversies; command-level favoritism; procurement and real-estate corruption narratives; nightlife “fixer” allegations; and continuing public-ethics fallout into 2026.

Greco alleges his anti-corruption commentary covered, among other topics:

  • high-level City Hall appointments and loyalty structures;

  • allegations of procurement steering and no-bid expansion patterns;

  • allegations of real-estate regulatory capture and benefits-for-favors exchanges;

  • NYPD command crisis events and alleged influence pipelines;

  • and federal/state investigative actions concerning senior public officials and affiliates.

The complaint pleads that as Greco’s chronology-based reporting reached wider audiences, retaliatory messaging, online aggression, and discrediting tactics intensified in parallel.

Alleged Selective Enforcement and the “Association” Double Standard

The complaint emphasizes what Greco calls a facially irreconcilable double standard: association treated as disqualifying when tied to him, but tolerated or strategically leveraged when useful to City power. Greco specifically pleads hypocrisy around the Roger J. Stone association issue—alleging that while City actors punished him for association-based grounds, Adams allegedly pursued access channels to the same political orbit for legal/political advantage.

Greco alleges this asymmetry is evidence of selective enforcement and retaliatory motive, not neutral rule application. The complaint frames this as a core inferential bridge between public criticism and adverse treatment: when rules are deployed against a critic but suspended for insiders, retaliatory purpose becomes plausible from timing, pattern, and differential treatment.

NYPD Retaliation Pattern, Command-Level Amplification, and Notice

In separate sections, the complaint pleads a command-level escalation timeline involving threatening communications, hostile social-media activity, alleged proxy/pseudonymous attacks, and attempts to burden Greco’s reputation and opportunities post-separation. Greco also alleges formal complaint activity, including a DOI complaint concerning Daughtry, and alleges ongoing digital targeting linked to protected anti-corruption reporting.

The complaint further alleges that, between March 2025 and present, Bhowmik repeatedly and falsely branded Greco a racist during the period of The Sal Greco Show broadcasts, with the purpose and effect of intimidating guests/viewers, suppressing participation, and chilling continued speech critical of Daughtry and the Tisch administration.

Greco alleges these acts were not merely rhetorical disputes but part of a retaliatory ecosystem designed to isolate him socially and professionally while discouraging public engagement with his reporting platform.

DOI/OIG Findings as Municipal Notice Evidence

The pleading relies heavily on public oversight findings to establish municipal notice and failure to remediate. It cites DOI/OIG findings concerning NYPD executive social-media governance deficiencies, including allegations of unprofessional, discourteous, demeaning, and potentially intimidating communications targeting critics; insufficient policy formalization; inadequate approval and registration compliance; insufficient executive training; and incomplete oversight controls.

Greco also references oversight findings relating to CRT governance gaps, including policy, mission-definition, training, recruitment, and accountability deficits. The complaint alleges that these findings put policymakers on notice of foreseeable constitutional risk in exactly the channels Greco alleges were used against him.

According to the pleading, corrective actions remained incomplete, informal, delayed, or uncodified, allowing retaliatory harms to continue during active litigation.

Credential/Status Harm and Stigma-Plus Theory

Greco alleges that retaliation extended beyond social media and included the use of credential/status machinery as an ongoing punitive tool. Specifically, he alleges that after his separation, the public “Removal for Cause” decertification listing functioned as a continuing stigma that harmed his reputation, employability, and professional standing while his federal case was pending.

The complaint frames this as structural retaliation, not a one-off event: a public label combined with concrete downstream harm. Greco further alleges he was denied a meaningful name-clearing process and that the continuing publication/maintenance of that status increased the personal and professional cost of speaking out and litigating.

As legal context, Greco cites Perros v. County of Nassau, 2025 WL 2533586 (E.D.N.Y. Sept. 3, 2025) as persuasive authority for the proposition that discretionary credential-linked determinations may be actionable when used in practice to impose stigma, reputational injury, and deterrence of protected activity. He pleads Perros by analogy—not as identical facts—and argues that “administrative” labels do not immunize conduct when the practical effect is punishment and chilling of protected speech.

Monell Theory: Policy, Custom, Ratification, Deliberate Indifference

The complaint alleges municipal liability under Monell on multiple paths: policy/custom, persistent practice, failure to supervise/train/discipline after notice, ratification by senior officials, and deliberate indifference to obvious constitutional risk.

Greco pleads that challenged conduct:

  1. was known to and ratified by final policymakers;

  2. persisted despite repeated public notice and investigative events; and

  3. was executed through municipal channels/resources, including official and quasi-official social-media ecosystems, Legal Bureau-linked functions, and command-level coordination.

The complaint alleges these municipal failures were a moving force behind constitutional injury, including chilling effects, emotional distress, reputational damage, lost opportunities, and increased costs of federal civil-rights petitioning.

Challenge to Qualified Immunity: Greco’s Position on Text, History, and Accountability

Greco’s complaint does not treat qualified immunity as a minor procedural defense. He challenges it directly as a judicially created doctrine that conflicts with the original text of the Civil Rights Act of 1871, now codified at 42 U.S.C. § 1983. The operative command enacted by Congress states that any person who, under color of law, deprives another of constitutional rights “shall be liable to the party injured.” Greco’s position is that this is the controlling primary-law text and that it contains no “clearly established law” safe harbor.

Greco specifically challenges the modern qualified-immunity framework to the extent it requires victims to identify near-identical prior fact patterns before officials can be held accountable. In this case, he alleges retaliatory conduct executed through contemporary mechanisms—monitoring of The Sal Greco Show, proxy and pseudonymous social-media activity, targeted intimidation of guests and viewers, reputational attacks, and pressure affecting active federal litigation. His contention is that constitutional accountability cannot be defeated merely because officials used newer digital or hybrid methods not previously litigated in identical form.

Greco further alleges that permitting qualified immunity to bar claims in this posture would incentivize innovation in constitutional misconduct: the more novel the method of retaliation, the less accountability. Greco contends that result is irreconcilable with § 1983’s enacted liability rule and incompatible with the statute’s Reconstruction purpose—providing a federal damages remedy against state actors who violate federal rights.

Accordingly, Greco’s challenge is not abstract. It is targeted: he contests the application of qualified immunity to intentional, date-anchored retaliation and speech-chilling conduct by municipal officials and their affiliates, and he seeks adjudication on the merits under the liability standard Congress actually enacted.

Counts and Relief Sought

The complaint asserts claims for:

  • Count I: 42 U.S.C. § 1983 — First Amendment Retaliation (speech and petition);

  • Count II: 42 U.S.C. § 1983 — Procedural Due Process (stigma-plus/liberty interest);

  • Count III: 42 U.S.C. § 1983 — Municipal Liability (Monell);

  • Count IV: NYSHRL Retaliation;

  • Count V: NYCHRL Retaliation.

Relief requested includes declaratory and equitable relief, compensatory damages, punitive damages where available, attorneys’ fees and costs, injunctive measures halting further retaliation, cessation of retaliatory monitoring/targeting practices, and correction/removal/annotation of stigmatizing credential/status records to the extent authorized by law.

Greco also seeks structural safeguards, including training, supervision, and oversight reforms sufficient to prevent recurrence.

Why This Complaint Matters Beyond One Plaintiff

This filing presents a contemporary constitutional stress test: whether government actors can use hybrid power—official authority plus networked digital proxies—to discipline dissent without issuing a formal censorship order. Greco’s case theory is that in modern municipal governance, retaliation can be distributed, deniable, and still unconstitutional.

The complaint alleges a transition from traditional disciplinary action to ecosystem pressure: monitoring, tagging, amplifying hostility, smearing credibility, isolating critics, and burdening litigation through persistent reputational attrition. In that model, the First Amendment injury is cumulative and strategic, not always reducible to a single event.

The lawsuit therefore frames the stakes broadly: protecting the constitutional right to investigate, criticize, and petition against public officials without being subjected to state-linked intimidation and coordinated professional harm.

Counsel Perspective

Greco’s position is that constitutional protections are tested most when criticism is inconvenient, persistent, and effective. The complaint contends that anti-corruption speech cannot be treated as a trigger for municipal retaliation, whether executed through direct command channels or proxy ecosystems. It further alleges that where policymakers receive repeated notice and still permit recurrence, municipal liability follows.

The filing seeks both accountability for past harm and forward-looking guardrails against recurrence in New York City’s command and communications systems.

Media and Public Information

About The Sanders Firm, P.C.

Founded by civil-rights attorney Eric Sanders, The Sanders Firm, P.C. is a New York–based law firm concentrating on civil-rights, employment, and police-accountability litigation. The firm is known for handling complex cases involving racial discrimination, due-process violations, and institutional abuse of power, particularly where government actions undermine constitutional and civil-service protections.

The allegations set forth in the complaint are claims only and have not yet been adjudicated.

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Read the federal complaint

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