PGCPS - Allison Complaint Filed May 16 2011

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Case 8:11-cv-01329-PJM Document 1 Filed 05/16/11 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND __________________________ TRACY ALLISON 9719 SUMMIT CIRCLE APT 2C LARGO, MD 20774, Civil Action No. Plaintiff, v. BOARD OF EDUCATION OF PRINCE GEORGE’S COUNTY 14201 SCHOOL LANE UPPER MARLBORO, MD 20772, Defendant. __________________________ COMPLAINT COMES NOW Plaintiff through undersigned counsel states as follows: JURISDICTION AND VENUE 1. This is an action for dec
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  IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF MARYLAND __________________________TRACY ALLISON9719 SUMMIT CIRCLEAPT 2CLARGO, MD 20774,Civil Action No.Plaintiff,v.BOARD OF EDUCATION OFPRINCE GEORGE ’ S COUNTY14201 SCHOOL LANEUPPER MARLBORO, MD 20772,Defendant.__________________________ COMPLAINT COMES NOW Plaintiff through undersigned counsel states as follows: JURISDICTION AND VENUE   1.   This is an action for declaratory relief; injunctive relief, damages and to secure protectionof and to redress deprivation of equal protection rights secured by the Equal ProtectionClause of the Fourteenth Amendment to the U.S. Constitution.2.   This is an action for declaratory relief; injunctive relief, damages and to secure protectionof and to redress deprivation of rights secured by Title VI of the Civil Rights Act of 1964,42 U.S.C. § 2000d-7 et seq. The U.S. Department of Education has provided Marylandpublic schools with more than $1 billion under the American Recovery and Reinvestment Act of 2009. Prince George’s County Public Schools are receiving stimulus funds for the Case 8:11-cv-01329-PJM Document 1 Filed 05/16/11 Page 1 of 8   2 expressed purpose of creating jobs and maintaining existing ones. Title VI requires therecipients of federal funds to waive Eleventh Amendment sovereign immunity. 3.   This is an action for declaratory relief; injunctive relief, damages and to secure protectionof and to redress deprivation of rights secured by Title IX of the Education Amendmentsof 1972 [20 U.S.C. 1681 et seq.]. The U.S. Department of Education has providedMaryland public schools with more than $1 billion under the American Recovery and Reinvestment Act of 2009. Prince George’s County Public Schools are receiving stimulus funds. Title IX requires the recipients of federal funds to waive Eleventh Amendmentsovereign immunity.   4.   Venue lies in this District pursuant to 42 U.S.C. § 2000e-5(f)(3) and because the eventsand occurrences giving rise to this action occurred within this judicial district.Pendant Claims5.   This is an action for declaratory relief; injunctive relief, damages and to secure protectionof and to redress deprivation of rights secured by Maryland’s Intentional Infliction of  Emotional Distress laws.6.   This is an action for declaratory relief; injunctive relief, damages and to secure protectionof and to redress deprivation of rights secured by Maryland’s Negligent Supervision and Retention laws. PARTIES 7.   Tracy Allison is a employee of Prince George’s County Public Schools .8.   The Prince George’s County Public Schools are located in Prince George’s County, Maryland. Case 8:11-cv-01329-PJM Document 1 Filed 05/16/11 Page 2 of 8   3 STATEMENT OF CLAIMTracy Allison Introduction9.   Tracy Allison has been employed by Prince George’s County Public Schools since 2005.  10.   Ms. Allison joined Largo High School as a secretary in 2006.11.   Ms. Allison worked in the principal’s front office.12.   Ms. Allison is a thirty eight (38) year old African American woman.Hostile Work Environment13.   Principal Simpson-Marcus became the principal of Largo High School in 2007.14.   Principal Simpson-Marcus is an African American woman.15.   Principal Simpson-Marcus openly despised white teachers.16.   Principal Simpson-Ma rcus referred to a white English teacher as “poor white trash” and instructed her staff not to associate with him.17.   Principal Simpson- Marcus referred to a white science teacher as “Bozo”.  18.   Ms. Allison worked as Principal Simpson- Marcus’ front office secretar  y.19.   Ms. Allison came in contact with white teachers on a daily basis and treated them withdue respect.20.   Several times a week, Principal Simpson-Marcus called Ms. Allison “ chicken head ” , “bird”, “hood rat” and “ghetto” in the presence of faculty, staff, parents, and students.21.   The terms “ c hicken head” and “bird” are urban slang terms for slut, according to theUrban Dictionary website at www.urbandictionary.com.  22.   The terms “chicken head” and “bird” refer to the mot ion a woman’s head makes when she performs fellatio. Case 8:11-cv-01329-PJM Document 1 Filed 05/16/11 Page 3 of 8   4 23.   Ms. Allison was extremely upset by Principal Simpson- Marcus’ use of these terms in reference to her.24.   Ms. Allison considered the use of these slang terms as racial slurs.25.   Ms. Allison frequently cried when Principal Simpson-Marcus used these slang terms.26.   Nonetheless, Principal Simpson- Marcus continued to call Ms. Allison “chicken head” , “bird”, “hood rat”, and “ghetto” .Retaliation27.   In the spring of 2008, Ms. Allison began to complain about Principal Simpson-Marcus toWilliam Barnes, a Director of the High School Consortium.28.   Prince George’s County Public Schools did not conduct an investigation or take promptcorrective action.29.   Between 2008 and 2010, Ms. Allison complained to Mr. Barnes about PrincipalSimpson-Marcus at least a dozen times.30.   Principal Simpson-Marcus would back off for a few days and then continue to harass andthreaten Ms. Allison.31.   Principal Simpson-Marcus constantly threatened Ms. Allison with termination.32.   As a result, Ms. Allison developed severe panic attacks.33.   Ms. Allison had to seek medical treatment.34.   Ms. Allison ’s doctor prescribed medication s to her help her cope with the stress causedby Principal Simpson-Marcus.35.   In August 2010, Ms. Allison immediately transferred out of Largo High School in orderto get away from Principal Simpson-Marcus. Count I  –  Title IX - Hostile Work Environment (Sex) Case 8:11-cv-01329-PJM Document 1 Filed 05/16/11 Page 4 of 8
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