The mother of a 13-year-old girl whose daughter was sexually assaulted at a metro Atlanta youth shelter in 2022 is suing her daughter’s abuser, as well as his mother, who is the former director of the shelter, for assault and negligence.
The lawsuit also accuses several other county and state officials and agencies of negligence and conspiring to cover up the sexual abuse of multiple girls at the facility.
Caleb Randolph, 27, was convicted of statutory rape in May of 2024 after an investigation by Clayton County Police and the Georgia Attorney General found that over a period of months in 2022, he had groomed and sexually exploited a teen girl at Rainbow House, a shelter for homeless and vulnerable children in Jonesboro, Georgia where he was employed.
Randolph is the son of Mia Kimber, 57, the shelter’s former executive director, who is accused in the lawsuit of covering up his abuse of the girl, identified as “A.C.” Also accused of knowing about the ongoing abuse of multiple girls at the shelter and failing to report it are Tasha Mosley, the current Clayton County district attorney, who was reportedly the board chair of Rainbow House during the period when A.C. was abused, and Jeffrey Turner, the former chair of the Clayton County Commission, which funded the shelter.
The complaint, obtained by Atlanta Black Star, also charges Kimber, Mosley, and Turner with engaging in a civil Racketeer Influenced Corrupt Organization (RICO) enterprise with Rainbow House to systematically conceal reports of sexual abuse occurring at the facility.
The teen plaintiff’s troubles began on April 26, 2022, when her mother, “Q.C.,” newly arrived to Georgia, was seeking housing assistance, clothing and financial support from local churches for herself and her three children, and was connected with New Life Church and Community Center in Decatur.
After a church representative didn’t show up for a scheduled meeting at a local park that morning, the complaint says, Q.C. walked her daughter to nearby Lithonia Middle School, where A.C. was enrolled, and went back to the park to wait for the woman, who never showed up.
She did encounter police, who inquired about what she, her other two children and the family dog were doing in the park. Q.C. declined their offer to transport them to a hotel, telling them that she had already secured housing for the family, the lawsuit says.
But several hours later, Q.C. learned from the school principal that her daughter had been removed from school by two police officers and the Georgia Division of Family and Children Services (DFCS), and that a deprivation and child endangerment case had been opened.
Her daughter was initially housed at a DFCS office building in Atlanta for several days, while Q.C. and her other children relocated to a hotel.
The lawsuit says A.C. endured starvation, food poisoning and unfit living conditions while in DFCS custody, was not allowed to shower for several days, and had to wear the same clothes that she had on when she was taken from school.
On May 1, 2022, A.C. was relocated to the Rainbow House, an emergency shelter for children that collaborates with DFCS and other service providers to house, clothe, educate and support youth removed from their homes and parents and from difficult and dangerous situations, including child sex trafficking.
During that month, A.C. was abused, molested and sexually assaulted multiple times by Randolph, who worked in a direct service capacity at the shelter, often unsupervised, the lawsuit says.
Randolph had previously been fired and then rehired a week and a half later for “violation of policy at Rainbow House,” where he subsequently abused and sexually assaulted A.C., according to the complaint.
The abuse by Randolph of both A.C. and another minor at the facility was allegedly known by several people associated with Rainbow House who had a legal duty to act on and report it, including Kimber, who was Randolph’s mother and the executive director of the nonprofit at the time.
But Kimber did not report the abuse of girls in her care at the hands of her son to law enforcement or to any government authorities, as mandated by law, the lawsuit claims.
Nor did Mosley, who was announced as chair of the Rainbow House, Inc. board of directors in January 2022. At the time, she was also a prosecutor for Clayton County, where she currently serves as the district attorney. The lawsuit says Mosley received reports of abuse at the shelter, including reports about Randolph, and failed to properly investigate them or to report the allegations of abuse and negligence to police and state welfare authorities.
Randolph and Kimber were arrested in March 2023, almost a year after the alleged abuse, after Clayton police received an anonymous tip from a whistleblower after that individual “realized their reports were not being investigated,” Fox 5 Atlanta reported.
Mosley recused herself from prosecuting the Rainbow House employees, and Georgia Attorney General Chris Carr took over the case.
Randolph was indicted in March 2023 and convicted in May 2024 of statutory rape and improper sexual contact by an employee in the first degree, both felonies. He is currently serving a 30-year sentence, including 17 years of confinement in prison and 13 years of probation.
Kimber was fired by the Rainbow House board and initially charged in March of 2023 by Clayton Police with party to a crime of child molestation, statutory rape, sexual assault and sexual exploitation, as well as with failing to report the incident.
A spokesperson for state Attorney General Carr told Atlanta Black Star on Monday via email that “after a thorough review and investigation, an indictment was obtained charging Defendant Kimber with one count of Cruelty to Children in March 2025. The case remains open. For this reason, we’re unable to provide additional comment or information.”
Other local and state officials and agencies now face civil liability.
The lawsuit asserts that before A.C. was abused, in February of 2022, Jeffrey Turner, then chair of the Clayton County Board of Commissioners (and formerly the chief of police of Clayton County Public Schools) received a detailed anonymous complaint from a Rainbow House employee regarding “ongoing abuse” at the shelter, compiled by his executive assistant, Katrina Holloway.
The complaint says Holloway placed the report on Turner’s desk, and found it in his trash can the following morning.
Turner also had a legal duty to report the alleged sexual abuse at Rainbow House when he learned about it, the complaint says, noting that he was primarily responsible for approving government grants to fund operations at Rainbow House, many submitted by Mosley.
Defendants Kimber, Mosley and Turner continued to allow the employment of Randolph, who had direct, unsupervised access to the minors placed at the facility, by not speaking up or reporting the incidents, the lawsuit alleges, and their negligence and failures directly led to the teen girl’s physical and emotional injuries, including sexual assault, humiliation, stress, anxiety, mental anguish, economic losses, and loss of enjoyment of life.
The plaintiffs, A.C. and Q.C., seek a jury trial to award a judgment against the defendants of general, special and compensatory damages in excess of $1 million, as well as punitive damages and legal costs.
The plaintiffs are represented by Roger Soroka, of Soroka & Associates, and Bryan Sutlive, of Sutlive Law.
“This case isn’t just about one predator, it’s about a network of power that enabled him,” Soroka told Clayton News-Daily. “The District Attorney knew, Rainbow House leadership knew, the Department of Family & Children Services knew, and many others knew. They didn’t just look the other way – they actively covered up the repeated sexual abuse of a 13-year-old girl. This wasn’t just negligence, it was complicity.”
“This little girl was a child in crisis, placed in state care to be protected, but instead, was exploited, hidden away, and ignored,” said Sutlive. “Rainbow House and multiple people in power preyed on the most vulnerable — children with no stable homes, no consistent records, and often no one looking out for them. These weren’t just isolated failures; this was a deliberate targeting of kids who could disappear without anyone asking questions. That’s what makes this so dangerous and so evil, and we believe there are many more victims.”
The defendants have 30 days after being served with the complaint to file a response in Clayton County State Court.
Mosley told Fox 5 Atlanta in a written statement last week that she categorically denies all of the allegations in the lawsuit.
“The Board of Directors was not responsible for the day-to-day operations of the Rainbow House thus, was not involved in any manner with staffing other than the hiring of the Executive Director,” she said. “I was not the Chair of the BOD when M. Kimber was hired, but the BOD was notified by the Chair at the time that Ms. Kimber passed all required background screens.”
“There was no previous outcry or any other communication regarding this situation made known to the BOD or myself,” she continued. “The first that I heard of this situation was when I was notified that the Rainbow House was being searched (at the very moment of notification) under a search warrant based on an active investigation by Clayton County PD and that there were employee arrests expected. At the time I was made aware of the search warrant, I hadn’t been a member of the Board for several months.”
The lawsuit also accuses the Georgia Department of Human Services and its Division of Children and Family Services of negligence, claiming that DFCS failed to adequately supervise the minor plaintiff while in its custody, and to ensure that its employees and agents at Rainbow House were qualified, competent, adequately trained and following proper standards of care.
DFCS waited until March 15, 2023, to suspend Rainbow House from receiving new placements of children, “years after reports of abuse at the shelter were initially made,” the lawsuit claims, citing a 2024 U.S. Senate Judiciary Committee investigation on abuse and neglect in Georgia’s foster care system.
An agency spokesperson for the Georgia Department of Human Services told Atlanta Black Star in an emailed statement, “We can confirm that we have not been served, but it is not our practice to comment on pending or active litigation.”
Rainbow House is liable for negligently hiring, supervising and training Randolph, and negligently entrusting him with care for minors, including A.C., the complaint says, citing the nonprofit’s decision to fire Randolph for his “known inappropriate conduct” and then to re-hire him a week and a half later and give him unsupervised access to A.C. as one of it most egregious actions.
“Defendant Rainbow House was aware of previous abuse at the facility and did nothing to stop the abuse from happening again by their employee Defendant Randolph at Rainbow House,” the lawsuit says. By failing to report Randolph to DFCS for his alleged prior incidents of child abuse at the facility, “Rainbow House is liable for the subsequent abuse, physical assault and sexual assault of A.C. by Defendant.”
It is not clear what monetary damages plaintiffs can recover from Rainbow House, Inc., which declared Chapter 7 bankruptcy in June 2023, according to tax filings, and ceased operating in August of that year after losing its lease with Clayton County.
The nonprofit’s 2023 tax return listed income of $1.16 million, expenses of $1.75 million, and a revenue loss of nearly $700,000. All of its remaining physical assets were sold off in November 2023. Prior tax returns show that most of its funding came from state and local government. The commercial insurance carrier of Rainbow House, Inc. is unknown.
The lawsuit also faults defendant Clayton County, which, as a funder of a child-caring institution, “had a duty to exercise reasonable care in overseeing facilities to which it provided funding and for which it maintained oversight responsibilities, including ensuring the safety and welfare of children placed in such facilities.”
The county was charged with ensuring the shelter’s compliance with state regulations, including the adequate supervision and protection of children in its care; conducting proper background checks and screening of staff; training personnel; and the immediate reporting of incidents of abuse or neglect, and it failed to do so, the lawsuit says.
Meanwhile, the county continued to fund the shelter’s operations despite knowledge of regulatory violations and “failed to take corrective action when notified of abuse allegations,” the complaint contends.
Clayton County did not immediately respond to a request for comment.
Great Job Jill Jordan Sieder & the Team @ Atlanta Black Star Source link for sharing this story.
