Beruflich Dokumente
Kultur Dokumente
undersigned counsel, file this Complaint and Demand for Jury Trial against
JURISDICTION
1.
This action arises under Title VII of the Civil Rights Act of 1964, as
amended, 42 U.S.C., § 2000e (“Title VII”); the Civil Rights Act of 1991;
VII;
1981a; and,
2.
The venue of this action is properly in the United States District Court
1391(b) and Local Rules 3.4, because a Plaintiff resides in the State of
district/division.
ADMINISTRATIVE PROCEDURES
3.
issued its Notice of Right to Sue on March 3, 2017. Plaintiff Snow timely
files this action within ninety (90) days of receipt of the Notice of Right to
-2-
Case 5:17-cv-00208-MTT Document 1 Filed 05/31/17 Page 3 of 17
Sue on March 17, 2017. Plaintiff Campbell timely files this action within
ninety (90) days of receipt of the Notice of Right to Sue form the EEOC.
PARTIES
4.
within this judicial district. She was formerly employed by Cirrus Education
Group, Inc. as the SPED Coordinator and Testing Coordinator at the Cirrus
5.
and the State of Georgia. Plaintiff resides in Thomaston, Georgia. She was
6.
Defendant Cirrus Education Group, Inc. for profit entity formed under
the laws of the State of Georgia. At all times relevant to the allegations in
-3-
Case 5:17-cv-00208-MTT Document 1 Filed 05/31/17 Page 4 of 17
1870 Pio Nono Avenue, Macon, Georgia and employed fifteen (15) or more
FACTUAL ALLEGATIONS
7.
8.
9.
-4-
Case 5:17-cv-00208-MTT Document 1 Filed 05/31/17 Page 5 of 17
10.
Cirrus Education Group, Inc. and the Superintendent of the Cirrus Charter
Academy.
11.
12.
13.
14.
provides that the school Principal shall develop a Complaint Procedure for
-5-
Case 5:17-cv-00208-MTT Document 1 Filed 05/31/17 Page 6 of 17
harassment. In effect, there was no procedure other than orally reporting the
15.
employee/teacher contracts.
16.
17.
18.
bitches,” “crackers,” “Hitler lovers,” and “white nazis.” The text messages
also stated that the Cirrus Charter Academy would be an “all black school”
-6-
Case 5:17-cv-00208-MTT Document 1 Filed 05/31/17 Page 7 of 17
19.
Plaintiffs and their families if they reported the harassment. Perhaps most
during school hours – while anonymous the texts were clearly being sent by
20.
who took no action other than to refer the Plaintiffs to the Superintendent
Ashanti Johnson.
21.
racially charged and harassing texts and likewise reported the harassment.
22.
Principal Gail Fowler – again no action was taken to protect Plaintiffs from
-7-
Case 5:17-cv-00208-MTT Document 1 Filed 05/31/17 Page 8 of 17
23.
put in place, the Plaintiffs requested to address the School Board – which
they had been told in their employee orientation was the last place they
24.
school informed the Plaintiffs they would not be allowed to address their
25.
Plaintiffs also learned that they were being paid less than their
Education, and, in some cases held more certifications than their higher paid
African-American co-workers.
26.
After complaining about and reporting the race based harassment and
-8-
Case 5:17-cv-00208-MTT Document 1 Filed 05/31/17 Page 9 of 17
based on race constituted protected activity under Title VII and 42 U.S.C.
§1981.
27.
telephone system;
-9-
Case 5:17-cv-00208-MTT Document 1 Filed 05/31/17 Page 10 of 17
representations.
28.
- 10 -
Case 5:17-cv-00208-MTT Document 1 Filed 05/31/17 Page 11 of 17
29.
intensified Plaintiffs began having trouble sleeping, hair loss, weight loss
30.
Both Plaintiffs have been forced to seek medical care and counseling
for illnesses and symptoms related directly to the harassment and retaliation
in their workplace.
31.
32.
search for teaching jobs as Defendant has carried through on their threat to
33.
discrimination.
- 11 -
Case 5:17-cv-00208-MTT Document 1 Filed 05/31/17 Page 12 of 17
34.
herein.
35.
VII of the Civil Rights Act of 1964, as amended, and 42 U.S.C. 1981a.
35.
36.
faith.
- 12 -
Case 5:17-cv-00208-MTT Document 1 Filed 05/31/17 Page 13 of 17
37.
38.
Plaintiffs have been made the victims of acts that have adversely affected
39.
40.
herein.
41.
- 13 -
Case 5:17-cv-00208-MTT Document 1 Filed 05/31/17 Page 14 of 17
42.
43.
herein.
44.
employed by Defendant.
45.
VII.
46.
Defendant retaliated against Plaintiffs by, but not limited to, the
- 14 -
Case 5:17-cv-00208-MTT Document 1 Filed 05/31/17 Page 15 of 17
47.
Title VII.
48.
49.
have suffered lost compensation and benefits, lost future earnings, suffered
50.
51.
herein.
- 15 -
Case 5:17-cv-00208-MTT Document 1 Filed 05/31/17 Page 16 of 17
52.
Defendant through its conduct has directly and proximately caused the
Plaintiffs great emotional distress for which Plaintiffs have sought and
53.
distress.
54.
to be proven at trial.
(1) General damages for mental and emotional suffering caused by the
Defendant’s misconduct;
of said acts;
- 16 -
Case 5:17-cv-00208-MTT Document 1 Filed 05/31/17 Page 17 of 17
(3) Special damages and/or liquidated damages for lost wages and
I hereby certify that this pleading was submitted in Times New Roman 14pt
font as required by the Local Rules of this Court.
- 17 -