PGCPS - Mua Complaint - Filed May 5 2011

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Case 8:11-cv-01198-PJM Document 1 Filed 05/05/11 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND __________________________ JOSEPHAT MUA 2332 LONDON BRIDGE DRIVE SILVER SPRING, MD 20906, 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 f
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  IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF MARYLAND __________________________JOSEPHAT MUA2332 LONDON BRIDGE DRIVESILVER SPRING, MD 20906,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 VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq.3.   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 Maryland Case 8:11-cv-01198-PJM Document 1 Filed 05/05/11 Page 1 of 9   2 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 for the  express purpose of creating jobs and maintaining existing ones. Title VI requires therecipients of federal funds to waive Eleventh Amendment sovereign 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 Inten tional 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.7.   This is an action for declaratory relief; injunctive relief, damages and to secure protectionof and to redress deprivation of rights secured by Maryland’s Wrongful Discharge laws . PARTIES 8.   Josephat Mua is a former employee of Prince George’s County Public Schools. 9.   The Prince George’s County Public Schools are located in Prince George’s County, Maryland. EXHAUSTION OF ADMINISTRATIVE REMEDIES 10.   Plaintiff Josephat Mua, filed a timely complaint with the Equal Employment OpportunityCommission, Charge No. 12H-2010-00091, based on his national srcin (Kenyan) and Case 8:11-cv-01198-PJM Document 1 Filed 05/05/11 Page 2 of 9   3 retaliation. On February 8, 2011, EEOC issued a Notice of Right to Sue letter to Mr.Mua. Josephat Mua Introduction11.   Mr. Mua is a forty three (43) year old man who was born in Kenya.12.   Prince George's County Public Schools discriminated against Mr. Mua on the basis of hisnational srcin (Kenyan), and in retaliation for complaining about discrimination.13.   In 2001, Mr. Mua was hired as a substitute teacher by Prince George’s County Public Schools.14.   In 2002, Mr. Mua was promoted to the position of permanent teacher at Parkdale HighSchool.15.   From 2002 to 2006, Mr. Mua taught business courses at Parkdale High School.16.   Mr. Mau became Department Chair of the Business Department.17.   In April 2006, Mr. Mua was promoted to the position of Technology Coordinator atParkdale High School.18.   In July 2007, Mr. Mua was transferred to Laurel High School as an IT Technician and put in charge of all of the school’s IT systems and equipment.  19.   In September 2008, Mr. Mua reported to Interim Superintendent William Hite andExecutive Director Monica Goldson that the principal of Laurel High School wasallowing his staff to take possession of laptops and other IT equipment without everhaving to return them.20.   Mr. Mua was immediately reassigned to six elementary schools. Case 8:11-cv-01198-PJM Document 1 Filed 05/05/11 Page 3 of 9   4 21.   Officials at the High School Consortium told Mr. Mua that they would not investigate thedisappearance of the IT equipment.22.   In October 2008, Mr. Mua learned that an IT director was selling PGCPS laptops and ITequipment for personal gain.23.   On May 2, 2009, Mr. Mua told Superintendent William Hite that an elementary schoolprincipal was operating her own business at her school.24.   The principal was selling jewelry and meat and pressuring staff members, like Mr. Mua,to purchase her merchandise.25.   Super intendent Hite said to Mr. Mua, “You have your job and she has her job, so what’syour problem?”  26.   In June 2009, Mr. Mua was informed that he would be transferred to the PGCPS HelpDesk where he would help teachers solve IT problems over the phone.27.   In August 2009, Mr. Mua was transferred to the Help Desk.28.   Mr. Mua was supervised by Shanita Anderson, Help Desk Supervisor, and PierreDickson, Director of Technology Support Services.Hostile Work Environment29.   Beginning in September 2009, Mr. Mua was regularly subjected to derogatory commentsbased on his national srcin.30.   On several occasions, Mr. Dickson called Mr. Mua a “Fucking Nigerian” despite being told by Mr. Mua that he is Kenyan.31.   Mr. Dickson had previously circulated derogatory comments about Nigerians. Case 8:11-cv-01198-PJM Document 1 Filed 05/05/11 Page 4 of 9
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