PGCPS - Harding Complaint Filed May 16 2011

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Case 8:11-cv-01331-PJM Document 1 Filed 05/16/11 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND __________________________ HEATHER HARDING P.O. BOX 1312 LANHAM, MD 20703, 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 declaratory r
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  IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF MARYLAND __________________________HEATHER HARDINGP.O. BOX 1312LANHAM, MD 20703,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-01331-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 Constructive Discharge laws. PARTIES 6.   Heather Harding is a former employee of Prince George’s County Public Schools. 7.   The Prince George’s County Public Schools are located in Prince George’s County, Maryland. STATEMENT OF CLAIMHeather Harding Introduction8.   In 1997, Dr. Harding was hired by Prince George’s County Public Schools.   Case 8:11-cv-01331-PJM Document 1 Filed 05/16/11 Page 2 of 8   3 9.   Three years later, Dr. Harding was promoted to assistant principal.10.   Dr. Harding had consistently received satisfactory job performance evaluations throughout her twelve (12) year tenure with Prince George’s County Public Schools. 11.   Dr. Harding is a thirty seven (37) year old African American woman.Retaliation12.   In the fall of 2008, Dr. Harding was an assistant principal at Duval High School.13.   On September 8, 2008, Dr. Harding filed a sexual harassment complaint against the maleprincipal of Duval High School with her union.14.   Dr. Harding’s union was the Association of Supervisory and Administrative School Personnel (ASASP).15.   Doris Reed , the union’s executive director, scheduled a meeting with InterimSuperintendent William Hite to discuss Dr. Harding’s sexual harassment complaint.  16.   However, at the last moment, Ms. Reed informed Dr. Harding that Dr. Hite would not beattending the meeting.17.   The meeting was attended by Dr. Harding, Ms. Reed, and PGCPS human resourcesofficials.18.   On November 19, 2008, Ms. Reed delivered a copy of Dr. Harding’s sexual harassment complaint, a completed 4170 harassment claim form, directly to Dr. Hite.19.   On February 27, 2009, Dr. Harding met with Randy Thornton, Human Resource Directorof Principals and Assistant Principals.20.   Prior to sexual harassment incident, Dr. Harding had injured her back when she fell atschool due to a wet floor. Case 8:11-cv-01331-PJM Document 1 Filed 05/16/11 Page 3 of 8   4 21.   Mr. Thornton told Dr. Ha rding to “look for another job” because he could not accommodate her medical restrictions.22.   On March 3, 2009, Dr. Harding filed an EEOC complaint against Prince George’s County Public Schools based on sex, retaliation, and disability.23.   On March 12, 2009, Dr . Harding received written notification from Prince George’s County Public Schools that her salary would be reduced from $102,342 to $96,465,effective March 11, 2008.24.   On March 13, 2009, Dr. Harding met with an EEOC investigator.25.   The EEOC investigator conf  irmed a correlation between the date Prince George’s CountyPublic Schools received notice of Dr. Harding’s EEOC complaint and Dr. Harding’s salary reduction.26.   Prince George’s County Public Schools also transferred Dr. Harding from Duval High School to Gaywood Elementary School.27.   On April 14, 2009, Dr. Harding reported to Gaywood Elementary School.28.   The principal of Gaywood Elementary School was Sonya Harris.29.   Dr. Harding was assigned to a storage area instead of an office.30.   Principal Harris told Dr. Harding that, according to the Regional office, she would not beat Gaywood for long.31.   Several faculty members told Dr. Harding that Principal Harris had described her as a “problem” that would not be at Gaywood Elementary School for long.  32.   Dr. Harding met with Cathy Jones and other human resources officials.33.   Ms. Jones told Dr. Harding, “I don’t know what we are going to do with you.” Case 8:11-cv-01331-PJM Document 1 Filed 05/16/11 Page 4 of 8
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