The family of Ronald Silver II, who collapsed and died of hyperthermia last August 2 while working on his trash route, will announce later today it is filing a formal notice to Baltimore City of a pending lawsuit.

The notice, required by federal law, outlines the family’s claims that the Department of Public Works engaged in intentional and willful civil rights violations.

“For years, DPW has operated a system of labor that demands that its workers, many of whom have prior criminal convictions, perform grueling manual labor in dangerous, subhuman conditions for laughable wages. The agency has perpetuated a system where workers cannot ask for assistance, complain about their plight or even quit because, if they do, they face retaliation, termination, and jail time,” the family’s lawyer, Thiru Vignarajah, wrote in a four-page letter sent this morning to City Solicitor Ebony Thompson.

The family and Travis Christian, who worked with Silver on the day he died, will assert in the lawsuit that Mayor Brandon Scott and DPW violated the 13th amendment of the Constitution, which prohibits indentured servitude and slavery, as well as other civil rights statutes.

“The culture and conduct at DPW confirms a callous and willful indifference to human life; the agency’s policies and practices are designed to dehumanize and subjugate workers; and the effect is the equivalent of modern-day slavery,” the letter asserted.

At noon today, a press conference is scheduled to be held outside of City Hall by the Silver family and Travis Christian.

Threat of Prison

Vignarajah says solid waste workers were told not to complain about their work conditions or else they would face retaliation, termination and a return to prison.

“Supervisors and probation agents have confirmed that this was not merely the subjective, inchoate fear of sanitation workers, but an objectively reasonable concern because continued employment with DPW was effectively a condition of probation for many workers,” the letter contended.

“For many DPW workers, including Mr. Silver and Mr. Christian, working in Solid Waste was not a second-chance opportunity – it was their last chance job. Numerous DPW workers have serious criminal records and cannot obtain other employment. This is an open secret that DPW middle managers and agency leadership systematically exploit, leading them to state that DPW workers are dispensable and can be readily replaced.”

Silver collapsed at the doorstep of a house, begging for water, on a day when the heat index rose to 108 degrees Fahrenheit.

Baltimore Inspector General Isabel Mercedes Cumming issued a scathing report in March that revealed a lack of training in emergency response by DPW, which led to the missed warning signs that Silver was suffering from overheating before his death.

“The OIG found that DPW failed to provide heat training in 2023 and only provided virtual training to supervisors in 2024 after the OIG investigation began in June 2024. As a result, Mr. Silver, Mr. Christian (and Mr. King, the driver of the vehicle that day) received no heat-related training. The OIG further observed that DPW’s heat illness prevention plan was still in draft status eight months after Silver’s death,” Vignarajah wrote.

The letter also cited a fact-finding report by Conn Maciel Carey, a Washington law firm hired by Mayor Scott after Silver’s death.

The report found that DPW supervisors did not enforce cool-down rest breaks, older fleet vehicles had broken down air conditioning systems and the agency’s Rubicon communication devices frequently ran out of batteries, hindering emergency communication.

NOTE: The Brew has covered Silver’s death and work conditions at DPW extensively. Our stories can be found here.