Example of Racial Discrimination Lawsuit

Below is a sample legal complaint in racial discrimination lawsuit.

Remember that in order to bring suit in federal district court under Title VII, you must first obtain a right to sue letter from the Equal Employment Opportunity Commission (EEOC).

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U.S DISTRICT COURT FOR MARYLAND (NORTHERN DIVISION)

Ben Davidson :
855 Betts Drive, #176
Baltimore, Maryland 21207 :
Plaintiff, :
v. :
Jones Healthcare :
482 Evans Way, Suite #200
Baltimore, Maryland 21207 :

RACIAL DISCRIMINATION COMPLAINT

The Plaintiff, Ben Davidson, by and through her attorneys, Miller & Zois, LLC, sues the defendants Jones Healthcare. In support, plaintiff states as follows:

1. 1. Plaintiff Dr. Bed Davidson resides at 855 Betts Drive, Apartment #176 in Gwynn Oak in Baltimore City.
   2. Defendant resides at 482 Evans Way, Suite #200 in Baltimore City. The registered agent for this defendant resides at this same location.
   3. This racial and discrimination action is brought pursuant to Title VII of the Civil Rights Act of 1964, as amended. The jurisdiction of this Court is invoked by the plaintiffs pursuant to 28 U.S.C. §§ 1331, 1343(4) and 28 U.S.C. §§ 2201 and 2202. This lawsuit is brought pursuant to the “The Civil Rights Act of 1866,” 42 U.S.C. § 1981, and 1981a and The Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq., as amended by the Civil Rights Act of 1991. Equitable and other relief is sought under 42 U.S.C. 2000e-5(g).
   4. Plaintiff is an African-American citizen of the United States and a resident of the state of Maryland. Plaintiff was employed with Jones Healthcare as a primary care doctor for three years until he was terminated on January 3, 2018.
   5. On January 10, 2018, a Charge of Discrimination was filed with the Equal Employment Opportunity Commission (“EEOC”) alleging racial discrimination. On August 4, 2018 a Notice of Right to Sue letter was issued by the EEOC, a copy of which is attached hereto as Exhibit “A”.
   6. During his three years at Jones Healthcare, Defendants created an environment which encouraged and fostered a hostile work environment for Dr. Davidson due to his race. Such conduct was ongoing, open, and notorious. Simply put, racial discrimination is deeply embedded in Jones Healthcare. It is open, active, and unashamed. The harassment, abuse and discrimination are encouraged by Whirlpool management’s refusal to stop the misbehavior.
   7. African-Americans at Jones Healthcare was subjected to a stricter level of scrutiny than his similarly situated white co-workers. African-Americans were repeatedly reprimanded and disciplined for relatively minor mistakes. The same behavior from similarly situated white employees was largely ignored even when discovered.
   8. On or one supervisor telling a staff member that “blacks just cannot process paperwork efficiently. Plaintiff reported his concerns. Defendant failed to take effective remedial action in response to racially charged complaints. Instead, when Dr. Davidson complained, he was fired.
   9. Jones Healthcare is liable under Title VII for such harassment and discrimination because it knew, or should have known, of the racial harassment and discrimination but failed to take prompt and effective remedial action. Instead, it did just the opposite. It condoned, ratified and otherwise allowed the racially harassing and discriminatory behavior to continue. Although the plaintiff as not subjected to this, racial slurs were used during Dr. Davidson’s tenue at Jones Healthcare.
   10. As a result of the plaintiff’s good faith complaints and opposition to race discrimination and racial harassment, the defendant retaliated against the plaintiff by subjecting him to stricter scrutiny than his co-workers, to demeaning and hostile treatment, to wholly unwarranted negative performance feedback, to being subjected to unwarranted discipline, to being assigned weekend shifts and holidays, and, ultimately, his termination. Plaintiff was up for and should have received a promotion but was instead fired.

WHEREFORE, Plaintiff, Patricia Abram-Adams, respectfully requests that this Court enter judgment against the Defendant and provide the following relief:

1. 1. Award actual damages, including appropriate amounts of back pay and front pay and the money lost from the failure to promote
   2. Award compensatory for race discrimination, retaliatory discharge, wrongful termination, and hostile work environment
   3. Award costs and reasonable attorney
   4. Grant any and all appropriate relief, which the Court deems necessary and appropriate.

Demand for Non-Jury Trial

Plaintiff demands jury trial of all issues.

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