Skip navigation
Sign up to follow your favorites on all your devices.
Sign up

Taking a close look at the complaint against Brandon McManus, Jaguars

On Friday, two flight attendants employed by Atlas Air filed a lawsuit against the Jaguars and former Jaguars (now Commanders) kicker Brandon McManus. PFT has obtained and reviewed a copy of the complaint.

You can review it, too, if you like. Here’s the link.

The plaintiffs have opted to proceed under the Jane Doe pseudonym. That was a point of contention in the lawsuits filed three years ago against Deshaun Watson, because Watson argued he didn’t know who was accusing him of wrongdoing. In this case, that shouldn’t be an issue; the Jaguars and McManus should be able to discern without much effort or guesswork the names of the individuals who are suing.

The plaintiffs are both residents of Harris County, Texas. That would help explain the decision to hire Houston-based attorney Tony Buzbee.

At paragraph 9, the complaint makes this broad allegation: “The NFL is no stranger to scandal, especially when it comes to offenses against women. Despite a pervasive advertising campaign to the contrary, many of its players have been accused of committing heinous sexual crimes and transgressions. The NFL’s failure to properly address this undeniable culture of sexual harassment and violence against women led to the preventable and disgraceful sexual misconduct towards Plaintiffs at the hands of Defendant Brandon McManus.”

“The flight quickly turned into a party as Defendant McManus and a number of his teammates disregarded the flight attendants’ personal space, air travel safety, and federal law,” the complaint alleges at paragraph 12.

“Defendant McManus himself spent the 8-hour flight roaming the plane, and even entered the crewmember-only galley multiple times,” the complaint alleges at paragraph 12. “Defendant McManus recruited three flight attendants (not the Plaintiffs) to the party, passing out $100 bills to encourage them to drink and dance inappropriately for him. Based on information and belief, the three flight attendants drinking and dancing with Defendant McManus no longer work for Atlas Air Worldwide Holdings.”

Paragraphs 16 through 23 focus on allegations made by Jane Doe I. At paragraph 17, the complaint alleges as follows: “Defendant McManus first cornered Jane Doe I when the pilot indicated that turbulence required seatbelts for all individuals on the plane. When Jane Doe I belted herself into her designated jump-seat, Defendant McManus got up, sat next to her and began talking to her.”

Paragraph 18: “At this time, Jane Doe I had already observed Defendant McManus drinking with and sexualizing the other flight crew, and was very uncomfortable with McManus’s presence near her. Despite her obvious discomfort, Defendant McManus leaned in to kiss Jane Doe I. She quickly put her hand up to block herself from Defendant McManus’s attempted unwanted advances. She firmly told Defendant McManus to go away, and he did in fact leave her alone for a short period of time.”

Paragraph 20: “On two separate occasions, Defendant McManus grabbed Jane Doe I and ‘grinded’ on her. Each time, she could feel his erect penis through his clothes as he rubbed himself on her. Both incidents were unprovoked, unwanted, and reprehensible.”

Paragraph 22: “As McManus was grinding against her, Jane Doe I froze and made eye contact with another Jaguars player, who looked ashamed of his teammate’s behavior. McManus eventually stopped and walked away.”

Paragraph 23: “Defendant McManus’s second assault on Jane Doe I occurred during the flight’s second meal service. Defendant McManus came up behind her, grabbed her tightly by the waist, and rubbed his clothed but erect penis on her multiple times. Yet again, Jane Doe I could not move away because she was standing in a small aisle and was carrying a large tray.”

Paragraphs 24 through 30 focus on the allegations made by Jane Doe II. From paragraph 24: “Defendant McManus also targeted Jane Doe II when she was occupied with job duties and unable to move away from his violative conduct. When Jane Doe II was serving the flight’s second meal service, Defendant McManus approached her from behind, grabbed her waist, and ‘grinded’ on her.”

Paragraph 26: “Like Jane Doe II, she could feel Defendant McManus’s erect penis through his clothes as he rubbed himself on her. When Jane Doe II turned around and confronted Defendant McManus, he simply smirked and walked away. She was humiliated and embarrassed.”

The complaint includes three causes of action: (1) assault and sexual assault by McManus; (2) intentional infliction of emotional distress by McManus; (3) negligence and gross negligence by the Jaguars.

The Jaguars have been sued under the theory that the team had a duty of “ordinary care” to protect the plaintiffs against player misconduct. The team is accused of negligent hiring, training, and supervision of McManus, along with the broader claim that the team failed to create and maintain proper policies and procedures for hiring, training, and supervising employees — and for failing to adopt policies and procedures to protect flight staff from sexual harassment.

The case seeks compensatory and punitive damages. The reference at the outset of the complaint to a request for damages in excess of $1 million dollars is ultimately meaningless, other than to satisfy the court’s jurisdictional minimum. The jury will give the plaintiffs whatever the jury decides to give the plaintiffs, if anything.

McManus’s lawyer, Brett Gallaway, previously issued a denial of the allegations: “To be clear, these are absolutely fictitious and demonstrably false allegations made as part of a campaign to defame and disparage a talented and well-respected NFL player. We intend to aggressively defend Brandon’s rights and integrity and clear his name by showing what these claims truly are — an extortion attempt.”

McManus will eventually respond to the complaint, with a formal answer or a motion to dismiss. Eventually, a schedule will be put in place for the discovery process (i.e., depositions, requests for documents, requests for written responses, and similar devices) and eventual trial. Like any case, it could settle at any time.