UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF TENNESSEE

NASHVILLE DIVISION
BRANDOM WILSON,
Plaintiff,
v.
CITY OF GALLATIN AND
GALLATIN PUBLIC UTILITIES
Defendants.

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CASE NO. ____________________

JURY DEMAND

COMPLAINT

COMES NOW the Plaintiff, BRANDOM WILSON (hereinafter Wilson or Plaintiff)

by and through counsel, and for this Complaint against the Defendant(s), CITY OF
GALLATIN and/or GALLATIN PUBLIC UTILITIES (hereinafter Defendant Gallatin
and/or Defendant GPU) seeking relief for discrimination pursuant to Title VII of the Civil
Rights Act of 1964, 42 U.S.C. 2000 et seq. to correct unlawful employment practices on the
basis of race and to provide appropriate relief to Plaintiff who was adversely affected by such
practices.

Furthermore, Plaintiff seeks relief for retaliation by Defendants arising out of

opposition to such discriminatory conduct and/or pursuant to Title VI of the Civil Rights Act of
1964, 42 U.S.C. 2000d- 2000d-7
PARTIES
1.

Plaintiff, is a resident of the United States who resides in Gallatin, Tennessee.

Plaintiff is and was at all times relevant to this Complaint a citizen of the State of Tennessee and
a resident of Sumner County.

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2.

Defendant, City of Gallatin, is, upon information and belief, a governmental

entity within the meaning of the Tennessee Governmental Tort Liability Act, T.C.A. 29-20102(3)(a) et seq. and conducts its principle business at 132 West Main Street, Gallatin, Sumner
County, Tennessee, 37066. Susan High-McAuley may be served process as registered agent for
Defendant City of Gallatin.
3.

Defendant Gallatin Public Utilities is, upon information and belief, a

governmental subdivision of Defendant Gallatin as defined and/or set out in T.C.A. 29-20102(3)(a) et seq. and conducts its principle business at 239 Hancock Street, Gallatin, Sumner
County, Tennessee, 37066.
4.

Defendant Gallatin is the governing entity having authority over Defendant GPU

and at all times relevant to this action is liable for the acts and/or omissions of employees of the
Defendant GPU under theories of respondeat superior, agency, contract, and/or statute.
5.

Plaintiff performed his duties within the city limits of Gallatin, TN 37066.
JURISDICTION AND VENUE

6.

Jurisdiction of this Court is invoked pursuant to Title VII of the Civil Rights Act

of 1964, as amended (42 U.S.C. 2000e et. Seq.). This Court has jurisdiction over the claims
asserted herein pursuant to 28 U.S.C. 451, 1331, 1343, and 1367. The jurisdiction of this Court
is invoked pursuant to 28 U.S.C. 1343 (3) and (4), this action being authorized by 20 U.S.C.
1703 and 42 U.S.C. 2000c-8 and 1983 to redress the deprivation of the minor Plaintiffs
constitutional rights under the Fourteenth Amendment to the United State Constitution.
7.

Venue is proper before this Court pursuant to 28 U.S.C. 1391(b) in that a

substantial part of the events or omissions giving rise to the present claim occurred within this
judicial district.

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8.

On or about April 9, 2015, Plaintiff filed a charge of discrimination (No. 494-

2015-00995) and retaliation (No. 494-2015-01711) against Defendant(s) with the Equal
Employment Opportunity Commission (EEOC), alleging race discrimination and/or
retaliation.
9.

On or about January 10, 2016, Plaintiff received a notice of suit rights from the

Department of Justice Civil Rights Division and/or EEOC, advising him that he had 90 days to
file against Defendant(s) under Title VII.
10.

Plaintiff has filed a Complaint within the aforementioned 90 day right to sue

period and all conditions precedent to the institution of this lawsuit have been fulfilled.
11.
provisions of

At all relevant times, Defendants as employers were and are subject to the
Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000 et seq. to prohibit

unlawful employment practices on the basis of race.

Furthermore, Defendant(s) have

continuously operated their business in Tennessee and this jurisdiction with at least fifteen
employees.
12.

The unlawful discrimination and/or retaliation alleged below were committed

within the jurisdiction of the United States District Court for the Middle District of Tennessee,
Nashville Division.
13.

Plaintiff asserts he was discriminated against on the basis of race. As such,

Plaintiff falls within the protected class as a person and/or employee as defined in 42 U.S.C.
2000e(a) who applied for and accepted employment with Defendant(s).
14.

Under title VI of the Civil Rights Act of 1964 and its implementing regulations,

no individual may be excluded from participation in, be denied the benefits of, or otherwise be
subjected to discrimination on the grounds of race, color, or national origin under any program or

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activity that knowingly receives federal funds. In addition, the existence of a racially hostile
environment that is created, encouraged, accepted, tolerated, or left uncorrected by a recipient
also constitutes different treatment on the basis of race in violation of title VI.
15.

Defendants had notice through its agents and employees of the existence of a

racially hostile environment. Plaintiff reported the same to Mayor Paige Brown and human
resources without subsequent relief or appropriate remedial measures to redress such unlawful
practices of discriminatory conduct and/or disparate treatment.
16.

The racial harassment of Plaintiff was so severe, pervasive, and objectively

offensive that, when taken in conjunction with the deliberate indifference of Mayor Paige
Brown, City Attorney Susan High-McAuley, and director of human resources, it effectively
deprived him of equal access to employment opportunities and/or benefits provided by the city in
violation of 20 U.S.C. 1703 and/or Title VI of the Civil Rights Act of 1964, 42 U.S.C.
2000d- 2000d-7 and/or et seq.
17.

Defendants at all times relevant to this action was a knowing recipient of federal

funds as defined within Title VI of the Civil Rights Act of 1964 et seq.
STATEMENT OF FACTS
18.

The discriminatory conduct alleged herein occurred in connection with Plaintiffs

employment with Defendant as a meter reader working at Defendants office, 239 Hancock
Street, Gallatin, Sumner County, Tennessee, 37066
19.

Since at least October 6, 2014, Defendant(s) have engaged in unlawful

employment practices at its Gallatin, Tennessee location in violation of 703(a) Title VII, 42
U.S.C. 2000e-2(a) and/or Section 704(a) Title VII, 42 U.S.C 2000e-3(a).

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20.

Defendant(s) discriminatory practices include, but are not limited to: (1) creating

or permitting a hostile work environment heavily charged with discrimination; (2) maintaining
wages, job assignments and other conditions of employment that unlawfully operate to deny
equal opportunity to Plaintiff because of his race; and (3) creating a hostile, racially charged
work environment such that no reasonable person would be expected to endure. Plaintiff was
subsequently and summarily discharged for opposing such discriminatory practices.
21.

Plaintiff was hired to perform as a meter reader on or about October 6, 2014.

22.

Plaintiff was under the direct supervision of David McConnell as supervisor who

as a member of management had the authority to materially alter the terms and conditions of
Plaintiffs employment.
23.

David McConnell was under the direct supervision of David Gregory as

superintendent of public utilities who as a member of management had the authority to

materially alter the terms and conditions of Plaintiffs employment.
24.

Plaintiff was the sole African American employee employed by Defendant GPU.

25.

On or about October 6, 2014, Plaintiff was performing his duties as a meter reader

observing a more experienced meter reader named Nick (last name unknown). On the premises
of Defendant GPU, a number of employees were walking from one building to another. An
employee named Randy (last name unknown), bellowed look at that black boy with a
Mohawk! A number of employees laughed. Plaintiff responded if you are going to call me
anythingcall me a black man!

Randy responded that Plaintiff could identify him as a

cracker or white trash. Plaintiff responded with an objection and that he would refer to him
by his name Randy. A supervisor by the name Richie (last name unknown) discussed the

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incident with a number of employees. Plaintiff observed a number of employees laughing at

what they heard.
26.

In March 2014, Defendant GPU organized a catered lunch wherein employees

contributed and ate jointly. Plaintiff was without knowledge of this event and was not invited.
David Gregory as head of the department stated Plaintiff could not attend as his name was not on
a list nor contributed financially towards the catering. Defendants conspired to alienate Plaintiff
from organized events on the basis of his race thus giving rise to disparate treatment.
27.

In March 2014, Plaintiff was asked to sign a condolence card and requested to

contribute to a fund for the employee. Plaintiff inquired as to the purpose of the request. The
female employee responded that another employees father was deceased and funds were being
collected to assist him. Plaintiff inquired as to why there was no offer of condolence or
collection of funds for his father passing away in December 2014. In December 2014, Plaintiff
was instructed by supervisor David McConnell on four or five occasions to provide a copy of the
obituary for proof underlying Plaintiffs request for personal leave on the morning following his
fathers death. David McConnell further instructed Plaintiff to call in each day of his personal
leave while contending with funeral preparations. Upon information and belief, Defendant GPU,
did not request such proof from any white employees. Plaintiff was admonished to bring in the
obituary on the day of the funeral which Plaintiff complied while in his dress for the funeral.
David McConnell without empathy inquired of Plaintiff if he would be available to work the
following day. Approximately two or three days after requesting personal leave, Plaintiff
requested a single day of personal leave to attend the funeral to be held at a military base. David
McConnell admonished Plaintiff to bring additional proof of the military funeral.

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28.

Plaintiff was trained by another meter reader Nick (last name unknown). Plaintiff

was filling his position as Nick was transferring to sewer service. On the first day of Plaintiffs
employment, on or about October 6, 2014, Nick informed Plaintiff that a previous employee was
followed on his route by supervisors and/or employees and subsequently terminated. In March
2015, Plaintiff was being followed by a GPU truck. Plaintiff was on the property of a resident
reading a meter and observed this truck parked and/or idling at a stop sign for approximately five
minutes until they noticed Plaintiff observing them. Defendants did not perform such acts
towards white employees who were meter readers.
29.

Subsequent to the incident alleged in paragraph twenty-five, Plaintiff was at car

wash reading its meter and conversing with an individual Plaintiff knew. The conversation
lasted no longer than two or three minutes. Randy (last name unknown), identified in paragraph
twenty two, drove into the car wash and exclaimed what the fuck are you doing? Plaintiff
responded that he was performing his duties. Randy responded its not what it looks like to
melooks to me like you are running your mouth. Plaintiff responded that he was ahead one
day and half of reading meters on his route and that he was instructed at time of hire and/or
training that he could perform other duties or remain at the office when he was ahead consistent
with the same practice of white meter readers.
30.

April Sartain is a customer service manager with Defendant GPU. In March

2014, Ms. Sartain began reprimanding Plaintiff with print outs of meter reading reports. Ms.
Sartain inquired of Plaintiff as to whether he needed glasses and must be blind for inputting
false readings. Ms. Sartain reprimanded Plaintiff daily for allegedly inputting false readings.
Plaintiff consistently responded that she was mistaken and subsequently alleged to Defendant
GPU that the meter readings were duplicated or falsified. Plaintiff read approximately an

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average of three hundred meters per day. Meter readers had an average number of false readings
due to human error. Plaintiff was informed by a number of meter readers that they were never
reprimanded by April Sartain for false readings. April Sartain stated to Plaintiff that she was
watching him and pointed two fingers towards her eyes back to him gesturing such
observation.
31.

In March 2015, April Sartain inquired of Plaintiff where are you from?

Plaintiff responded Gallatin.

Ms. Sartain responded Nooooo.where are you from?

Plaintiff responded Gallatin, I was born at Sumner Regional. Ms. Sartain exclaimed to a
number of employees Oh my gosh yall he doesnt even know where hes from. Ms. Sartain
was clearly alluding to his national origin and/or race.
32.

In October 2014 through June 2014, Plaintiffs routes were continuously and

improperly uploaded into his handheld device utilized for inputting meter readings. April Sartain
had the primary responsibility and burden of uploading routes into each handheld device for each
meter reader. Plaintiffs trainer and fellow meter reader, Nick, stated to Plaintiff that he was not
aware of any meter reader having a technical error with routes uploaded into their handheld
device. Plaintiff consistently complained to Tyler (last name unknown) in the presence of April
Sartain about technical errors with the handheld device. Ms. Sartain failed to take any remedial
measures to repair the technical error.
33.

On or about April 9, 2015, Plaintiff with counsel disclosed the allegations averred

herein to Mayor Paige Brown. The director of human resources and City Attorney for Defendant
Gallatin was present at the meeting. Plaintiff had requested the meeting via electronic mail to
these individuals.

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34.

On or about April 9, 2015, Plaintiff exercised his rights in filing a charge (charge

no. 494-2015-00995) of discrimination on the basis of race with the Equal Employment
Opportunity Commission.
35.

On or about April 20, 2015, Plaintiff received a yellow safety vest with reflective

material containing no markings of GPU or Gallatin Public Utilities. Plaintiff had requested at
the time of hiring to have a uniform that each meter reader donned for their shift. The uniform
identified meter readers to homeowners while on their property reading meters that they were
Defendant GPU employees. Plaintiff was never provided a uniform until the final month of
employment and only after filing of a second EEOC charge. A meter reader by the name of
Zach (last name unknown) inquired of Plaintiff as to why he did not wear a uniform and wore
personal clothing. Plaintiff responded that he was not provided a uniform after numerous
requests. Zach responded you fucking bullshitting me.you dont have a t-shirt or uniform?
Plaintiff responded no. Zach demonstrated consternation while responding new guys hired
got uninforms referencing new employees hired subsequent to Plaintiff but in a different
department.
36.

On or about June 5, 2015, supervisor David McConnell, asked Plaintiff to speak

with him. Mr. McConnell admonished Plaintiff about driving on wrong side of the road and
nearly causing a motor vehicle accident. Meter readers drive on the opposite side of side roads
with limited traffic volume to avoid stepping out and being hit by a car. Mr. McConnell threated
a written reprimand if it occurred again. Plaintiff overheard Mr. McConnell on the phone with a
resident complaining about the same act. Mr. McConnell stated to the resident that it was
necessary for meter riders to drive on the left side of the road while reading meters. Plaintiff was
instructed by his trainer, Nick, that this routine act was proper in a city truck with markings of

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Defendant(s). David Gregory overhead a conversation with Plaintiff and Mr. McConnell and
admonished Plaintiff to drive with the flow of traffic. Plaintiff responded with an inquiring
tone, so stop in traffic, step out in traffic, putting my life in danger, to cross the street and read a
meter?

Mr. Gregory responded yes.

Richard (last name unknown) overheard the

conversation and stated wow, well I have been doing it wrong all the years Ive worked here.
A number of meter readers continue with this practice subsequent to Plaintiffs effective
termination date of July 31, 2015.

Plaintiff has received photos captured by a personal

acquaintance demonstrating a white Defendant GPU employee on November 13, 2015

performing the same act for which Plaintiff was admonished.
37.

On or about June 6, 2015, Plaintiff inquired of David McConnell as to when the

written reprimand would be purged from his employment or personnel file. Mr. McConnell
appeared dismayed by the inquiry and perplexed responding I dont knowno one has ever
asked me that question before. Mr. McConnell could not refer to a policy, custom, or practice
of how long a reprimand would remain in an employees file or what condition precedent must
be satisfied purging the same. This discriminatory conduct demonstrates unlawful employment
practices and a course of disparate treatment on the basis of race.
38.

On or about June 11, 2015, David McConnell admonished Plaintiff about not

improving his rate of false readings within immediate proximity of other employees. Mr.
McConnell stated all other white meter readers were improving except you. Mr. McConnell
identified a street that a female resident resided on complaining about Plaintiff driving on the left
side of the road. Mr. McConnell rebuffed and/or rebutted Plaintiffs attempts to correct him and
demonstrate the allegations were mistaken and/or false.

This discriminatory conduct

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demonstrates unlawful employment practices and a course of disparate treatment on the basis of
race.
39.

On or about June 22, 2015, Plaintiffs work vehicle popped out of its park

position and rolled down a hill hitting a fence. Plaintiff followed his procedures in reporting the
incident to his supervisors. Plaintiff passed a drug and alcohol test. Plaintiffs coworkers
informed Plaintiff that an alcohol test was usually administered only to those having a
commercial drivers license (CDL). Plaintiff did not have a CDL. This discriminatory conduct
demonstrates unlawful employment practices and a course of disparate treatment on the basis of
race.
40.

On or about June 29, 2015, Plaintiff inquired as to when his vehicle with a

transmission malfunction would be repaired as it posed as a danger on the road. Plaintiffs

immediate supervisor, Richie (last name unknown), responded that he doubted it would be
repaired as it still ran. At this time, however, Plaintiff had direct knowledge of other vehicles
being repaired for air conditioning malfunction.

This discriminatory conduct demonstrates

unlawful employment practices and a pattern of disparate treatment on the basis of race.
41.

On or about June 29, 2015, Plaintiff was formally reprimanded by David

McConnell in the presence of Richie for allegedly failing to read a sprinkler meter at a residence
in the upscale Fairvue Plantation. This meter was flagged as a dead meter due to two previous
false readings. David McConnell instructed Plaintiff to sign the written reprimand to which he
refused. Mr. McConnell rebuffed Plaintiffs explanations attempting to reconcile the issue and
threatened termination for failing to sign. Mr. McConnell personally inspected the meter and
spoke to the resident inquiring about his usage.

Mr. McConnell recounted the residents

statement that he had been using the sprinkler since May. The additional usage read by the meter

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reflected less volume of water necessary to fill an outdoor childrens pool. Plaintiff asked for an
opportunity to have an attorney review the written reprimand. Mr. McConnell refused with a
response Can you not read?....you are always threatening me with a lawyer. Mr. McConnell
contacted his superior David Gregory who instructed Plaintiff to sign the written reprimand.
Plaintiff once again refused to sign it. This discriminatory conduct demonstrates unlawful
employment practices and a course of disparate treatment on the basis of race.
42.

On or about June 25, 2015, David McConnell instructed Plaintiff to appear in his

office. April Sartain informed him that Plaintiff failed to read another meter. There was no
warning or opportunity for Plaintiff to respond.

Plaintiff was instructed to sign a written

reprimand to which he refused. This discriminatory conduct demonstrates unlawful employment

practices and a course of disparate treatment on the basis of race.
43.

On or about July 24, 2015, Plaintiff emailed the director of human resources and

Mayor Paige Brown that the pattern of discriminatory conduct persisted and became severe and
pervasive. Plaintiff communicated his contention that there existed a hostile work environment
heavily charged with racism. Plaintiff was approached by David Gregory on his route who
inquired as to what Plaintiff was doing. Plaintiff responded that he was about to begin reading
meters on his route and expected to be completed around 11 a.m. Mr. Gregory responded under
a false pretext that he observed Plaintiff sitting in a truck on his cell phone. This discriminatory
conduct demonstrates unlawful employment practices and a course of disparate treatment on the
basis of race.
44.

On or about July 31, 2015, Plaintiff received a written reprimand from David

Gregory alleging lost hand held meter reading device containing sensitive customer data.
Upon information and belief, a meter reader by the name of Ben had misplaced a similar

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device temporarily without consequence, progressive discipline or adverse employment action.

Upon information and belief, a number of meter readers have misplaced the same and/or similar
device without consequence, progressive discipline or adverse employment action. Mr. Gregory
alleged that a female citizen returned the device after finding it off premises and/or on a street.
Plaintiff inquired which street it was alleged to have been found on. Mr. McConnell, April
Sartain, David Gregory, and other employees failed to respond and/or how the female citizen
was aware it was a GPU device. The GPU device had no clear conspicuous markings indicating
it belonged to Defendant. Mr. Gregory acknowledges in the affirmative to Plaintiffs assumption
that it may have been dropped onto the street. Plaintiff does not contend or affirm that he in fact
misplaced the device.

Upon information and belief, Defendant continued its severe and

pervasive pattern of discriminatory conduct and/or disparate treatment under the false pretext of
this reprimand.
45.

Plaintiff requested to observe this reprimand referenced in paragraph 41 to which

David Gregory refused. Plaintiff responded that he would not sign it.
46.

Upon information and belief, David Gregory expressed negative sentiments

and/or comments about Plaintiff filing the EEOC charge alleging racial discrimination.
47.

On or about August 3, 2015, David McConnell and Richie as a witness, presented

a reprimand to Plaintiff regarding the allegation of misplacing the device. Mr. McConnell
inquired of Plaintiff if he or Richie had offended Plaintiff. Plaintiff affirmed a continuing severe
and pervasive pattern of discriminatory conduct. Plaintiff stated that Mr. McConnell would not
understand the effect upon Plaintiff looking out looking in. Mr. McConnell responds that my
people lost this country so I can understand a whole lot more than you think. Mr. McConnell
then incredulously expounds upon a president of the United States run us off to a reservation

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somewhere or kill usso I can understand a whole lot more than you think I can. Mr.
McConnell arrogantly proclaims to have walked in Plaintiffs proverbial shoes by comparing a
historical event to a clear and present series of circumstances personally endured by Plaintiff.
Mr. McConnell instructed Plaintiff to go to personnel department at city hall. Mr. McConnell
proclaimed to Plaintiff that he was the cockiest person Ive ever met. Plaintiff did not say
anything disrespectful or insubordinate to deserve such an insulting and inappropriate remark.
Mr. McConnell inquired of Plaintiff as to whether Plaintiff had gone to city hall on Friday, July
31, 2015. Mr. McConnell clearly demonstrated actual knowledge that Plaintiff would not be on
duty for a period of time on Friday, July 31, 2015, for some purpose, as he acknowledged
Plaintiff may have been going to city hall. Mr. McConnell stated Plaintiff needed to go to city
hall because some matter apparently did not get cleared up from Plaintiffs communications
city hall on Friday, July 31, 2015.
48.

On or about July 31, 2015 and again on August 3, 2015, at city hall and/or the

human resources department, a reporter with the Gallatin News Examiner inspected Plaintiffs
personnel file consistent with a form captioned personnel file inspection report executed by
Amy Summers who is employed by Defendant. Apparently this is a uniform document placed
into an employees file disclosing it was inspected by a particular individual.
49.

On or about August 3, 2015, at approximately 8:21 a.m., Plaintiff appeared before

Debbie Johnson at the human resources department. Ms. Johnson stated that David Gregory
recommended dismissal for insubordination having a tone during a counsel referenced
above. Plaintiff was accused of walked off his job, at 9:11 a.m. Ms. Johnson read aloud the
notice of intended dismissal that Plaintiff had called and left her a voicemail on Friday, July
31, 2015, at approximately 8:40 a.m. or in that approximate time frame. Ms. Johnson called

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Plaintiff back on Friday, July 31, 2015, at approximately 9:46 a.m. stating I was returning your
call. Ms. Johnson clearly was on actual notice of this omission in the notice and failed to to
take affirmative action in redressing it.

Plaintiff attempted to proffer facts clarifying this

omission without resolution. Defendant asserts that they had to spontaneously call in someone
else to finish his route as it is scheduled to be completed by the end of the day of the 31 of the
month. Defendant was on notice that Plaintiff would not be able to complete his route through
actual knowledge of going to city hall. Nick (last name unknown) was assigned to complete
the route with sufficient time and notice. Plaintiff was clearly terminated on the pretext of
walking off the job without permission to leave in the course of this severe and pervasive
pattern of discriminatory conduct and/or disparate treatment.
50.

On August 3, 2015, Plaintiff was terminated from employment by Defendant.

51.

Defendant asserts that Plaintiffs effective date of termination was July 31, 2015.

52.

On August 3, 2015, Plaintiff filed EEOC charge number 494-2015-01711 alleging

discrimination based on retaliation for filing EEOC charge number 494-2015-00995 on April 9,
2015.
53.

On or about August 7, 2015 and again on August 25, 2015, Defendant attempted

to intimidate Plaintiff from pursuing his statutory rights by sending City of Gallatin police
officers to his residence to deliver a letter stating that failure to appear at any pre-dismissal
hearing would constitute as a relinquishment of any request for a pre-dismissal hearing. On
August 25, 2015, the officer placed his hand on his firearm in its holster while getting out of his
vehicle in his driveway.

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54.

The effect of the unlawful employment practices complained of herein has been to

deprive the Plaintiff of equal employment opportunities and to otherwise adversely affect his
status as an employee because of his race as an African American. Such discrimination practices
were performed intentionally with malice and/or reckless indifference to the federally protected
rights of Plaintiff.
55.

The basis for termination proffered by Defendant(s) is false and serve as a pretext

for termination therefore deserving no credence as a legitimate non-discriminatory act.

56.

Defendant(s) are strictly liable for the acts averred herein because of because of

David McConnell with authority to materially alter the terms and conditions of employment for
employees under his supervision.
57.

Plaintiff has suffered damages as a result of Defendant(s) discriminatory actions

in excess of $75,000.00.
58.

As a result of the direct and/or proximate acts and/or deliberate indifference of

Defendant alleged which are incorporated herein as if specifically set out, Plaintiffs suffered
damages, which include, but are not limited to, the following:
a. General damages for pain, suffering, mental anguish, anxiety, public
humiliation, emotional distress, and embarrassment;
b. Irreparable harm;
c. Loss of personal reputation;
d. Loss of back wages;
e.

Loss of insurance benefits;

f.

Loss of other fringe benefits;

g.

Loss of Future earnings and front-pay;

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h.

Loss of time and money in endeavoring to protect himself from Defendants

unlawful discrimination, including costs and reasonable attorneys fee of this action.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff prays for the following relief against Defendant(s):
1.

Declaration that the Defendant(s) violated Plaintiffs rights with regard to race

discrimination pursuant to Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000 et seq. and
relief for retaliation by Defendants arising out of opposition to such discriminatory conduct
and/or pursuant to Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d- 2000d-7.
2.

Compensatory damages with prejudgment interest to Plaintiff for all salary, back

pay, front pay, and benefits lost due to Defendant(s) unlawful actions in an amount not less than
$200,000.00 or to be determined;
3.

Damages to Plaintiff for emotional distress, loss of enjoyment of life,

embarrassment, and humiliation in an amount to be determined;

4.

Punitive damages to Plaintiff in an amount to be determined;

5.

Award to Plaintiff the costs and disbursements of this action, including reasonable

attorneys fees, costs, and expenses; and

6.

Such other and further relief as the Court deems just and proper.
Respectfully submitted,
/s/Roland Mumford
Roland Mumford BPR 026495
Law Offices of Roland Mumford & Assoc.
242 West Main Street, No. 223
Hendersonville, TN 37075
Phone: 615.348.0070
Fax: 614.246.4110
Email: roland@mumfordlaw.net
Attorney for Plaintiff

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