PGCPS_-_Ball-Rice_Complaint_filed_on_May_23_2011

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Case 8:11-cv-01398-PJM Document 1 Filed 05/23/11 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND __________________________ DARLENE BALL-RICE 611 HARRY S. TRUMAN DRIVE UPPER MARLBORO, 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
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  IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF MARYLAND __________________________DARLENE BALL-RICE611 HARRY S. TRUMAN DRIVEUPPER MARLBORO, 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-01398-PJM Document 1 Filed 05/23/11 Page 1 of 10   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.   Darlene Ball-Rice is a current employee of Prince George’s County Public Schools .8.   The Prince George’s County Public Schools are located in Prince George’s Count y,Maryland. Case 8:11-cv-01398-PJM Document 1 Filed 05/23/11 Page 2 of 10   3 STATEMENT OF CLAIMDarlene Ball-Rice Introduction9.   Darlene Ball- Rice has been employed as a secretary by Prince George’s County PublicSchools since October 1994.10.   Darlene Ball-Ric e was a principal’s secretary at Largo High School .11.   Ms. Ball-Rice is a forty nine (49) year old African American woman.Hostile Work Environment12.   Principal Simpson-Marcus continuously humiliated her African American secretaries bycalling them “chicken head” , “bird”, “hood rat” and “ghetto” in the presence of faculty,staff, parents, and students.13.   Terms like “ c hicken head” and “bird” are urban slang terms for slut, according to the Urban Dictionary website at www.urbandictionary.com.  14.   These terms refer to the motion a woman’s head makes when she performs fellatio.15.   Principal Simpson-Marcus specifically referred to one African American secretary as a “Palmer Park  hood r at”.  16.   The term “ hood r at” is an urban slang te rm for ghetto slut, according to the UrbanDictionary website at www.urbandictionary.com.  17.   Ms. Ball-Rice and the other African American secretaries found slang terms like “chicken head”, “bird”, “hood rat” and “ghetto” that Principal Simpson-Marcus to beracially offensive.White Teachers Targeted for Harassment and Termination18.   Principal Simpson-Marcus became the principal of Largo High School in 2007. Case 8:11-cv-01398-PJM Document 1 Filed 05/23/11 Page 3 of 10   4 19.   Principal Simpson-Marcus is an African American woman in her early forties.20.   Principal Simpson-Marcus openly despised older white teachers.21.   Principal Simpson-Marcus regularly refer to older white teachers as “poor white trash”,“dirty white man”, “old white ass”, and “old white bitch”.  22.   In the presence of her staff, Principal Simpson-Marcus pledged to get rid of theseteachers.23.   The method for getting rid of these teachers would be to give them negative jobperformance evaluations.24.   Principal Simpson-Marcus stated that she had the support of Superintendent Hite andExecutive Director Monica Goldson.25.   Principal Simpson-Marcus particularly despised Jon Everhart, a white English teacher.26.   When referring to Mr. Everhart, Principal Simpson-Marcus would occasionally say to her staff, “I can’t stand that motherfucker”.  27.   Principal Simpson- Marcus openly referred to Mr. Everhart as “poor white trash”.  28.   In the spring of 2010, Mr. Everhart became ill at school.29.   Mr. Everhart stopped by the  principal’s office to submit the forms that would allow himto take the remainder of the day off.30.   Ms. Ball-Rice accepted the completed forms from Mr. Everhart before he left the schoolto go home.31.   Days later, Principal Simpson-Marcus summoned Mr. Everhart to her office and accusedhim of not submitting the required forms.32.   Ms. Ball-Rice, who had accepted the required forms from Mr. Everhart, spoke up in Mr. Everhart’s defense.   Case 8:11-cv-01398-PJM Document 1 Filed 05/23/11 Page 4 of 10
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