IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA Civil Action No. 1:14-cv Plaintiff,

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1 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 1 of 30 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA Civil Action No. 1:14-cv MELISSA J. MANN, v. Plaintiff, WINSTON-SALEM STATE UNIVERSITY, an agent of the State of North Carolina, AMENDED COMPLAINT and JANICE SMITH, individually, Defendants. NOW COMES Plaintiff, Melissa J. Mann, by and through counsel, and brings this action for violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., against Winston-Salem State University ( WSSU ), an agent of the State of North Carolina and a member of the University of North Carolina Group of Universities which operate throughout North Carolina and for violations of 42 U.S.C and 42 U.S.C against Defendant Janice Smith in her individual capacity. In support of her claim Plaintiff alleges as follows: NATURE OF THE ACTION 1. This is an action by Melissa J. Mann for inter alia violation of Title VII of the Civil Rights Act of 1964, violation of 42 U.S.C. 1981, and violation of 42 U.S.C

2 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 2 of Plaintiff alleges in this action that Defendant Smith and agents and servants of WSSU committed the following acts which violate the aforementioned statutes: a. Continuously and maliciously blocking the Plaintiff from receiving tenure and promotions and raises. b. Wrongfully disparaging and defaming the Plaintiff and misstating her credentials to others. c. Failing to prevent others from wrongfully disparaging and defaming the Plaintiff. d. Failing as Managers of other agents and servants to ensure that the Defendants subordinate agents did not create and maintain a hostile work environment and retaliate against the Plaintiff for reports and violations of these claims. e. Failing as Managers to discipline and remove employees who continued and maintained discriminatory actions against members of a certain race. f. Forcing Plaintiff to work under terms and conditions of employment that were different from other similarly situated employees. g. Retaliating against Plaintiff for opposition to practices of the employer which violated the federal anti-discrimination laws and for filing a claim for harassment with the EEOC. JURISDICTION AND VENUE 3. Plaintiff re-alleges and incorporates by reference the preceding paragraphs as if fully set forth herein. 2

3 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 3 of This Employment Discrimination lawsuit is brought under Title VII of the Civil Rights Act of 1964 for employment discrimination on the basis of race (Caucasian/White) and for retaliation for the Plaintiff s exercise of rights under this statute. The claim for violation of the Plaintiff s Civil Rights is brought pursuant to 42 U.S.C and 42 U.S.C (deprivation of Civil Rights under Color of State Law). 5. This Court has jurisdiction of Plaintiff s federal claims pursuant to 28 U.S.C and Venue is proper in this Court pursuant to 28 U.S.C Plaintiff resides in this district and a substantial part of the events giving rise to the underlying claim at issue took place in this district. THE PARTIES 7. Plaintiff re-alleges and incorporates by reference the preceding paragraphs as if fully set forth herein. 8. Plaintiff Mann is a citizen of the state of North Carolina and resides in Forsyth County, North Carolina. 9. Defendant Winston-Salem State University is an agent of the State of North Carolina and a member of the University of North Carolina Group of Universities. 10. Upon information and belief, Defendant Dr. Janice Smith is a citizen and resident of Forsyth County, North Carolina. 11. Plaintiff timely filed Charges of Discrimination with the Equal Employment Opportunity Commission ( EEOC"), designated as EEOC Charge No

4 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 4 of Plaintiff has exhausted her administrative remedies and on September , the EEOC issued Notice of Right to Sue to Plaintiff. (See attached Exhibit 1 ). FACTUAL ALLEGATIONS 13. Plaintiff re-alleges and incorporates by reference the preceding paragraphs as if fully set forth herein. 14. Plaintiff is currently employed as an Assistant Professor at the University of North Carolina Pembroke. She is a Caucasian/White Woman. 15. Plaintiff first received a Bachelor of Science in Human Resource Management from Binghamton University. She then earned a Masters degree in Organizational Leadership from the Mercy College School of Business. Following this, Plaintiff completed her Ph.D in Organizational Studies with a Specialization in Human Resource Management at SUNY Albany in Plaintiff s Dissertation was entitled A Quantitative and Qualitative Analysis Identifying Antecedents of Work Ethic Beliefs and the Relationship between Work Ethic Beliefs and In-Role and Extra-Role Work Behavior: New Work Ethic Dimensions and Scale Introduced. 16. Plaintiff was hired as an Assistant Professor of Management at Winston- Salem State University in August of Prior to this employment, Plaintiff taught at the State University of New York ( SUNY ) Albany, Marist College and Mercy College. 18. Prior to August 2010, but unknown to Plaintiff at the time of hire, there was a longstanding culture and problem with harassment of non-african American 4

5 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 5 of 30 Employees at Winston-Salem State University by certain members of the School of Business, including inter alia Dr. Janice Smith and other members of the WSSU s tenure committee for the School of Business. 19. For example, on February 11, 2010, Dr. Amanda Gray, an individual who held the Plaintiff s position immediately preceding the Plaintiff, was forced to resign because of the discriminatory and hostile behavior towards herself and other white non-tenured faculty. See attached letter dated February 11, 2010 sent by Dr. Amanda Gray to Dr. Thomas O. Jones the interim chair of Department of Management and Marketing attached as Exhibit Dr. Gray identifies Dr. Janice Smith as the individual responsible for creating a hostile work environment for Dr. Gray throughout Dr. Gray's three years in the Department of Management and Marketing. Dr. Janice Smith is a tenured professor at Winston-Salem State University. Dr. Smith is African-American and is a member of the Reappointment and Tenure Committees for the School of Business and Economics, as well as the Tenure Committee for the University. During this three-year time period numerous complaints were lodged against Dr. Smith for her behavior by Dr. Thomas Jones, Dr. William Carden, Ms. Beverly D. Johnson Lindsey, Dr. Amanda Gray, and Dr. Suresh Gopalan, among others. 21. Upon being hired by WSSU, it became immediately apparent to the Plaintiff that she was not welcome as a professor in the Department due to the fact that she was white and not African-American. It became increasingly clear to Plaintiff after interacting with Dr. Smith and speaking with several of the individuals who had formerly lodged complaints against Dr. Smith or who had been the subject of her 5

6 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 6 of 30 harassing behavior that Dr. Smith would block any senior faculty position that Plaintiff applied for or aspired to. 22. Upon hiring and throughout her employment the Plaintiff was asked by managers of the WSSU to submit her ideas and thoughts for modifying a business and management curriculum for the classes that she would be teaching. 23. Many of the classes in the curriculum were designed by Dr. Janice Smith and upon information and belief, Dr. Smith saw Plaintiff's hiring as a threat to her curriculum and disagreed with the hiring of a white female for the position rather than the hiring of minority professor. Dr. Smith expressed these opinions regularly to her friends and colleagues and made it clear she was not happy with the hiring. 24. The same concerns about Dr. Smith retaliating for proposed curriculum changes had been previously raised by several of the individuals named in paragraph 13 of this Complaint surrounding the resignation of Dr. Amanda Gray in 2008 and Upon information and belief, after talking with Dr. Smith about the Plaintiffs hiring, Dr. Gloria Clark, a friend of Dr. Smith, without warning or provocation, accosted the Plaintiff in her classroom in front of all the students. It was not immediately clear to the Plaintiff what Dr. Clark was upset about as she screamed at the Plaintiff in front of her students, stuck her finger in the Plaintiff's face menacingly, and stood over the Plaintiff in a threatening manner. The Plaintiff asked Dr. Clark several times to please leave the classroom and she finally complied. Following class when the Plaintiff left the room Dr. Clark was waiting for the Plaintiff in the hallway. The situation appeared so threatening that one of 6

7 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 7 of 30 the Plaintiff s male students asked the Plaintiff if she needed him to walk her to her office. Not wanting to involve the student the Plaintiff told him that she was fine. Despite this, the student was so concerned for the Plaintiff s safety he proceeded to follow her all the way up to her office. 26. The Plaintiff did not understand the animosity that was being expressed towards her and had no idea of the reasons for Dr. Clark s bizarre behavior at that point. This incident occurred on or about September 28 or 30, Plaintiff immediately reported this incident to the Dean and the chair of the management department and student statements and accounts of the event were collected by administration. Plaintiff reported this behavior to the appropriate administrators. No disciplinary actions were taken against Dr. Clark or Dr. Smith nor were any steps taken to ensure that future instances of this type did not occur. 28. On or about October 1, 2010, during a School of Business meeting, discussions were held about curriculum development issues. The Plaintiff was present along with many of her colleagues in the school of business including Dr. Janice Smith and Dr. Sharon White. Like Dr. Smith, Dr. White is an African- American professor at Winston-Salem State University and upon information and belief a close friend of Dr. Smith. When Plaintiff offered curriculum and other suggestions regarding the needs of the students at Winston-Salem State University she was told immediately by Dr. Smith that she would not understand the needs of a historically black college or university student as she was not a member of a protected class. 7

8 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 8 of Following this statement by Dr. Smith, this sentiment was further voiced by Dr. Sharon White, who commented that the some professors (while looking at Plaintiff) were not able to discuss or provide insight regarding the dress code at the University because they were not representative of the traditional historically black college and university professor. 30. Following this meeting the Plaintiff was so upset she decided to speak with Dean Bailey, the Dean of the School of Business and Economics and her supervisor. She proceeded to have a private meeting with Dr. Jessica Bailey and Dr. Thomas Jones, the then Chair of the Department to express her concerns regarding the comments of the senior faculty to other faculty members which insinuated that the Plaintiff s skin color would prohibit her from being a successful educator at Winston-Salem State University. 31. Roughly ten days later on October 12, 2010 a string of hostile false and derogatory s from Dr. Smith were sent to other members of the faculty. These s were personal attacks against the Plaintiff and stated that the Plaintiff was not qualified to provide input or teach any human resource courses within the University. In response to these s, Dr. Bailey and several professors admonished Dr. Smith for the venomous content of her s. 32. Despite this admonition, administration did nothing else to prevent the continued harassment of the Plaintiff by Dr. Smith following these s. 33. On the next day, October 13, 2010, the senior faculty made the decision to not reappoint the Plaintiff in the following academic year. This committee included Dr. Smith who had even gone so far as to tell people on the committee that the 8

9 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 9 of 30 Plaintiff did not have a proper dissertation. In response to this, the Plaintiff was forced to give Dr. Allen in administration a copy of her dissertation to contradict Dr. Smith's assertions and establish her qualifications with the University. 34. Dr. Smith s bullying behavior and harassment continued unabated for the next two months. During the entire time Plaintiff has worked for WSSU, Dr. Smith has regularly glared at, yelled at, demeaned, threatened, put down, dismissed and otherwise aggressively bullied the Plaintiff. 35. Roughly two months later on January 5, 2011 the Plaintiff attempted to speak with Dr. Smith after the School of Business faculty meeting. The Plaintiff knew that regardless of her past with Dr. Smith that she would need to work together with Dr. Smith on HR program issues and changes as Dr. Smith was senior faculty in the Department which contained the HR program. 36. Plaintiff explained to Dr. Smith that she hoped that they could put the past in the past and work together on the upcoming semester. In response, Dr. Smith interrupted her and stated are you done? She then proceeded to put her hand in the Plaintiff's face and walk away and refused to talk to the Plaintiff regarding any HR or curriculum issues. 37. This pattern of harassment continued in February and March of 2011 and caused the Plaintiff to have several conversations with Ed Hanes, Equal Employment Opportunity Commission Officer, regarding the filing of an EEOC claim against WSSU. In response to these conversations, Mr. Hanes told the Plaintiff that it would be prudent to file a claim with the EEOC. However, the 9

10 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 10 of 30 Plaintiff told Mr. Hanes that she was afraid of retaliation and stated that she would have to give it further thought. 38. Mr. Hanes told the Plaintiff that he would begin the paperwork and process to begin filing the EEOC claim so that it would be ready to go if necessary. 39. Following this interaction, Mr. Hanes asked the Plaintiff to be part of a focus group for white staff and faculty, which was being conducted by the EEOC and University to examine the prevailing perceptions of diversity and inclusion and examine possible enhancements in this area. The Plaintiff accepted the invitation. 40. The Plaintiff attended the EEOC focus group proposed by Mr. Hanes on March 30, The focus group was conducted by Dr. Benjamin D. Reese, Jr., a consultant hired by the University to address diversity issues. Dr. Reese was hired by the University in June 2011 to prepare an assessment of the diversity challenges facing Winston-Salem State University. Most white participants voiced the opinion that they were treated differently from their African-American counterparts. 41. During the focus group and after speaking with the Plaintiff, Dr. Reese encouraged the Plaintiff to continue working with Mr. Hanes due to the inappropriateness of the actions by senior faculty including Dr. Smith. That same day, on March 30, 2011, Plaintiff told Mr. Hanes to file the EEOC paperwork telling him that she would pursue the matter. 42. Unfortunately, the next day, March 31, 2011, it was announced that Mr. Hanes had been let go from his position as EEOC officer. Due to the suddenness of this termination, the Plaintiff was apprehensive to follow up on her initial EEOC claim to make sure the paperwork had been filed correctly. 10

11 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 11 of Dr. Reese's report was completed in June of In that report, Dr. Reese concluded there were serious issues related to diversity at Winston-Salem State University. He stated there was a sentiment on campus that non-job-related factors such as race were being considered in employment actions at the University and that there were situations where highly qualified white employees were passed over for promotion in favor of less qualified black employees. This is the exact situation that befell the Plaintiff. 44. Following this, on August 12, 2011, Plaintiff was attending the Academy of Management meeting in San Antonio Texas. She encountered Dr. Smith at the School of Human Resource Management social event. She attempted to engage Dr. Smith in a pleasant conversation. In response, Dr. Smith stated that she tried to be nice to the Plaintiff in the beginning of the school year but that Plaintiff had rejected her offer to collaborate and had picked her side. Dr. Smith went on to tell the Plaintiff that that if she wanted to get tenure she needed to stop hanging out with the chickens and start flying with the Eagles. Dr. Smith insinuated that the Plaintiff's friendships with untenured faculty and instructors such as fellow professor Dr. Bill Carden who had previously complained about Dr. Smith s discriminatory practices would prohibit her from being voted on favorably by senior faculty and Dr. Smith's friends on the tenure and promotion board. Dr. Carden is also Caucasian/White. 45. On or about September 8, 2011, Dr. Smith sent a false and derogatory regarding Plaintiff and Dr. William Carden s suggestions to improve the human resources curriculum. In these s which Dr. Smith circulated to the entire 11

12 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 12 of 30 faculty, Dr. Smith stated falsely that the Plaintiff is unqualified to teach classes in the department and stated that the Plaintiff and Dr. Carden had ruined the Department of Human Resources program at Winston-Salem State University. 46. The Plaintiff did not initially know that the had been sent until another faculty member asked the Plaintiff how it felt to be slapped by Dr. Smith again. The fellow faculty member then stated that the Plaintiff s face must hurt. In response to this the Plaintiff read the and became extremely upset. The Plaintiff knew that she had not been reappointed in the previous year based primarily on the actions of Dr. Smith and her friends and their racial discrimination of her. She was worried that Dr. Smith s comments would again ruin her reputation and influence the senior faculty to again deny her reappointment. 47. In response the Plaintiff and Dr. Carden sent a joint letter to Dr. Bailey on September 19, 2011 providing a point by pointed response to Dr. Smith's . Despite this letter and the previous admonitions that Dr. Smith had received against this type of and behavior nothing was done to discipline Dr. Smith or prevent her from continuing to harass the Plaintiff. 48. Similar incidents happened in February, March and April of During this period, Dr. Smith repeatedly stressed that the Plaintiff was incapable of understanding and educating the students at Winston-Salem State University based primarily on the fact that she is not African-American. Dr. Smith has also continued to denigrate her qualifications and defame her to other faculty members for the purpose of denying her senior faculty status and to prevent her tenure 12

13 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 13 of 30 reappointment. It is clear Dr. Smith s main goal is securing Plaintiff s termination as she did to Dr. Amanda Gray in Finally, in September of 2012, Dr. Smith was removed by the administration of the WSSU from any personal discussions related to the Plaintiff based on her false complaints against the Plaintiff and the subsequent investigations related to those complaints. Without Dr. Smith's input into the re-evaluation process, Plaintiff was reappointed on a 7-0 vote. 50. Despite this, Dr. Smith and her friends have continued to harass the Plaintiff at every opportunity and continue to bully the Plaintiff. 51. For example on October 4, 2012, Dr. Smith falsely reported via and during in person conversations with senior faculty that the Plaintiff had made changes to a course for the previous spring and that the Plaintiff should therefore be teaching it because she needed to be developed. This was not true. Dr. Smith further falsely stated that the Plaintiff engaged in behaviors that hurt the department and circumvented the curriculum process. These reports by Dr. Smith damaged the Plaintiff's reputation and credibility with senior faculty. She further stated in these conversations that Plaintiff was unqualified to teach these classes and should not be teaching HR classes for fear of depriving the students of the opportunity to successfully enter the field of human resources. None of these statements were true but instead represented an attempt by Dr. Smith to hurt the Plaintiff's credibility and reputation and to have her removed from the University. 52. Another agent and employee of the WSSU who is also a friend of Dr. Smith is Dr. Khojasteh. At the urging of Dr. Smith, Dr. Khojasteh has reported to the 13

14 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 14 of 30 entire department that the search committee had harbored a member who invited and promoted a friend to apply. He and Dr. Smith named the Plaintiff as this member who allegedly acted in an inappropriate manner. He further alleged that the committee and Plaintiff had broken the law by taking these actions. None of these allegations are true. 53. In conjunction with these reports Dr. Smith also wrote a letter the same day questioning the credentials and ethics of the entire committee and referring specifically to the Plaintiff as the individual committing the alleged misconduct. 54. Following this, on or about Thursday, January 17, 2013, Dr. Mak Khojasteh, a friend of Dr. Smith and senior faculty member, approached Ms. Beth Schneider, an employee of Defendant and member of the Junior Faculty who had worked at Winston-Salem State University for more than three years. Dr. Khojasteh asked if he could speak with Ms. Schneider. Ms. Schneider found this strange as neither Dr. Khojasteh nor Dr. Smith had spoken to her in over three years. Dr. Khojasteh went on to tell Ms. Schneider that Plaintiff was working behind her back to try to promote her friend. Dr. Khojasteh told Ms. Schneider that if she did not get the job she would know who was against her and who caused it. Dr. Khojasteh went on to tell Schneider that Plaintiff was degrading her teaching ability and was doing the same to Dr. Carden. 55. Over the next few weeks Dr. Smith and Dr. Khojasteh began saying hi to Ms. Schneider and talking to her frequently. Each time they would remind Ms. Schneider that Plaintiff was working against her and Dr. Carden. However, when it became clear that Schneider would not assist them in their attacks against Plaintiff 14

15 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 15 of 30 they opposed her promotion and appointment to a faculty position that she had applied for. 56. On January 31, 2013 Dr. Khojasteh and Dr. Smith both wrote another derogatory about the search committee and the Plaintiff specifically. Dr. Smith followed this up with another about the alleged tainted search process and claimed that the process was unethical in a further attempt to discredit the Plaintiff. 57. On March 1, 2013 the Plaintiff had a meeting with Dr. Smith in a further attempt to work together on the curriculum development. Rather than talking about the curriculum development Dr. Smith again used the opportunity to denigrate the skills of the Plaintiff and to inform her how unqualified she was (in Dr. Smith s estimation) to teach. 58. In this conversation, Dr. Smith told the Plaintiff that she needed to stop hanging out with people like Dr. Bill Carden because they were not going to be around soon anyway. She went on to threaten the Plaintiff s job, stating that she needed to be more careful with who she was aligning herself if she wanted to get tenure. 59. Following this, Dr. Smith went to talk to Dr. Pearson after the meeting and requested that the Plaintiff be allowed to take MBA classes from Dr. Smith even though Dr. Smith knew that Plaintiff had no need of further classes, had a PhD in the subject matter to be taught and was not interested in taking any additional classes from Dr. Smith. 15

16 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 16 of In this conversation, Dr. Smith again denigrated the Plaintiff s qualifications despite the fact the Plaintiff at all times had the exact same qualifications as Dr. Smith. 61. Following this, at the request of the administration, on April 4, 2013, Dr. Smith, Dr. Pearson and the Plaintiff had a meeting to discuss the HR curriculum and updating the description for one of the management classes. 62. During this conversation Dr. Smith called the Plaintiff a liar and said the Plaintiff was treacherous and deceitful. Further, throughout the entire conversation Dr. Smith acted agitated and aggressively pointed her finger in the Plaintiff's face. She went on to slam her fingers on the table in front of Plaintiff in an aggressive manner and yell that the Plaintiff had ruined the HR program and that she was not qualified to make changes. When admonished for her tone by Dr. Pearson, Dr. Smith became defiant and started yelling about how she was not going to be embarrassed by the Plaintiff anymore. 63. Dr. Smith stated to Dr. Pearson that the Plaintiff had embarrassed her in front of her colleagues by having her removed from the Plaintiff s reappointment decision and continued to state that the Plaintiff was ruining the HR program. She continued this behavior despite several admonitions and despite being told by Dr. Pearson that the dialogue was not productive. Dr. Smith then yelled at the Plaintiff to leave the room but Dr. Pearson told the Plaintiff to stay as Dr. Smith continued to berate her and rant about her. The conversation ended with Dr. Smith saying she wanted nothing to do with either Dr. Pearson or the Plaintiff or the program anymore and slamming the door on her way out. 16

17 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 17 of Following this, on April 11, 2013, Dr. Smith wrote an which publicly denigrated the Plaintiff in her efforts to modify the curriculum and stated that she was stripping the program and that Junior Faculty should not be involved in curriculum modification. Similar s were sent on April 16, April 18, and April 19 with no action to prevent them being sent by any person in administration. 65. Following this, on May 21, 2013 Dr. Smith came to the Plaintiff's office. Dr. Smith stated that she wanted to apologize for being heated in the meeting with Dr. Pearson on April 4. She then stated that the Plaintiff should have left the meeting when she told her to. Plaintiff responded that her supervisor had asked her to stay so she did what she was asked to do. In response, Dr. Smith replied that Dr. Pearson was no longer in charge of the Management and Marketing Department. She was referring to the fact that Dr. Pearson stepped down from the position as department chair to return to her duties in administration shortly before the conversation. Dr. Smith then said that the Plaintiff should listen to her because regardless of what people in administration tell her they are not going to continue to be there to support the Plaintiff and they will have no impact on her tenure decisions. 66. Dr. Smith went on to say that she and the other senior faculty were going to be there no matter what and they would be the ones making the decision on Plaintiff s tenure. She stated that the Plaintiff had a tremendous hole to dig herself out of, and stated that Plaintiff had created a bad reputation with the department on campus. 17

18 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 18 of Smith went on to say that other people in the department that are supportive of the Plaintiff such as Dr. William Carden would not be around for much longer but that she will continue to be there and be the one who ultimately controls the Plaintiff's future at Winston-Salem State University. 68. This conversation was so intimidating and threatening to the Plaintiff that she became too frightened to follow up on her harassment claim. 69. In August 19, 2013, the Plaintiff s worst fears were realized as Dr. Smith and Dr. Khojasteh were put in charge of the Management Human Resource Major and Concentration. Both of these faculty members are minorities and have been previously the subject of EEOC investigations that are currently open and/or other lawsuits for employment discrimination. 70. On August 20, 2013 Dr. Smith again wrote an to the Plaintiff's new supervisor and Department Chair Dr. Moula Cherikh. In the , Dr. Smith purported to remove the Plaintiff from oversight of a student group and indicated she would be taking over the organization. 71. At no point has Dr. Smith had any authority to remove the Plaintiff from any appointed position. She sent the to try to bully the Plaintiff out of her position. 72. On August 22, 2013 Dr. Khojasteh falsely told the entire department that the junior faculty violated Winston-Salem State's ethical standards and asked for different performance standards to be put in place for the Plaintiff and other junior faculty members. In response, the chair stated that the junior faculty would be 18

19 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 19 of 30 evaluated on the same three categories as every other employee: service, teaching, and research. 73. In response, Dr. Khojasteh and Dr. Smith then pronounced that a junior faculty member has violated multiple ethical codes at the University and stated that this conduct needed be part of the evaluation of that faculty member (referring to Plaintiff). 74. While this exchange was occurring, several faculty members turned towards the Plaintiff because they knew that Dr. Khojasteh was referring to the Plaintiff. No actions were taken against Dr. Smith or Dr. Khojasteh for the defamatory comments, bullying behavior, and harassment. 75. On June 2, 2014, it was announced in a public that the Plaintiff s program was to be placed on hold for fall This harassment only intensified into retaliation when the Plaintiff formally filed her EEOC complaint August 27 th with the University EEOC Officer first in hope the issues could be resolved internally. 77. Following this, on November 13, 2014, Plaintiff s students were denied access to the writing lab because Plaintiff had allegedly not made an appointment while the other African American professor s students were permitted to use the center. In response, the Plaintiff again complained to her superiors about this behavior. No action was taken by her superiors to prevent this continued harassment and disparate treatment of Plaintiff. 78. Additionally, the Plaintiff learned in November 2014 that she was passed over for a pay raise while other individuals who upon information and belief are 19

20 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 20 of 30 African-American and who are less qualified to receive a pay raise have received a raise. 79. All of the aforementioned actions were taken by agents and servants of the WSSU, a State entity, and were taken and performed within the course and scope of their employment and in their official capacities as State agents. 80. On May 5, 2015, Plaintiff resigned from her position at Winston Salem State University due to the constant harassment and discrimination against her. 81. All of the aforementioned conduct was the moving force of and did directly, proximately and legally cause the Plaintiff to suffer the following damages and adverse employment actions: a. Plaintiff was denied reappointment in 2010 at the department level based on the conduct of the agents and servants of WSSU listed above and Defendant Smith; b. Plaintiff has lost credibility and has suffered grave injury to her reputation among her colleagues at Winston-Salem State University based on the conduct of the agents and servants of WSSU and Defendant Smith; c. Plaintiff has been passed over for pay raises and job promotions based on the conduct of the agents and servants of WSSU and Defendant Smith; d. Plaintiff has had her chances at securing tenure and senior faculty status at WSSU irreparably harmed based on the conduct of the agents and servants of WSSU and Defendant Smith and due to the placing of her program on hold; 20

21 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 21 of 30 e. Plaintiff s Human Resource Management Degree program has been eliminated in order to justify her removal from employment; f. The Plaintiff s reputation and marketability with another University have been irreparably harmed by the conduct of the agents and servants of WSSU and Defendant Smith; g. Plaintiff has suffered grave emotional and physical injury for which she has been treated by a medical professional as a result of the continued bullying and harassment of agents and servants of WSSU and Defendant Smith. Plaintiff has suffered from extreme anxiety, depression and physical exhaustion as a result of the conduct of the agents and servants of WSSU and Defendant Smith; h. Additionally, the Plaintiff was pregnant during a large part of the WSSU s conduct. Upon information and belief, her son was born premature as a result of an emergency C-Section. Upon further information and belief, the Plaintiff s OB-GYN has informed her that the Plaintiff s admission into the hospital, pregnancy complications, and the subsequent premature birth of her child were proximately caused by her physical response to the anxiety and stress caused by the agents and servants of WSSU and Defendant Smith; i. Finally, Plaintiff was forced to seek new employment and take a different position that, upon information and belief, will slow her down on the tenure track. Plaintiff, upon further information and belief, has had to 21

22 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 22 of 30 move for her new position, and thus, has incurred moving expenses and taken a loss on her house; j. All of the above damages have damaged the Plaintiff in an amount greater than $10,000. CAUSES OF ACTION AND CLAIMS FOR RELIEF Retaliation in Violation of The Civil Rights Act of 1964 (Defendant WSSU) 82. Plaintiff re-alleges and incorporates by reference the preceding paragraphs as if fully set forth herein. 83. In conversations with employees of Defendant WSSU, Plaintiff asserted her right to be free from racial harassment and race discrimination, practices made unlawful under Title VII of the 1964 Civil Rights Act. 84. The actions of Defendant WSSU as set forth herein constitute retaliation against Plaintiff for the assertion of her right to be free from racial harassment and race discrimination. Such retaliation is in violation of Title VII of the 1964 Civil Rights Act, 42 U.S.C. 2000e-3(a). 85. Plaintiff, a white female, began the EEOC process on March 30, 2011, alleging discrimination in employment. The EEOC s investigation of Plaintiff s charge has been completed and she has received a Right to Sue Letter within the 90 days prior to the institution of this action. 86. Plaintiff has exhausted all administrative prerequisites to bringing this action insofar as it seeks individual and class relief for violation of Title VII of the Civil Rights act of 1964, as amended, 42 U.S.C. 2000e et seq. 22

23 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 23 of Defendant WSSU engaged in retaliation against Plaintiff with either malice or with reckless indifference to the federally protected rights of Plaintiff to be free from racial discrimination in the workplace, as set forth in 42 U.S.C. 1981A(b)(1). 88. By reason of the conduct of Defendant WSSU, Plaintiff has suffered emotional damage and injury and tremendous mental anguish and humiliation, and has lost the pay and benefits associated with the status of a tenured faculty member at WSSU. 89. Plaintiff is entitled to all of her lost benefits of employment including, but not limited to, back pay, front pay, health insurance, life insurance, and retirement benefits. 90. Plaintiff is entitled to compensatory damages as provided by the Reconstruction Era Statutes, 42 U.S.C. 1981, in an amount in excess of ten thousand dollars ($10,000.00) as a proximate result of Defendants conduct alleged herein. 91. Plaintiff is entitled to punitive damages as provided by the Reconstruction Era Statutes, 42 U.S.C. 1981, in an amount in excess of ten thousand dollars ($10,000.00) as a proximate result of Defendant's conduct as alleged herein. 92. Plaintiff is further entitled to recover reasonable attorney's fees, the costs and the expenses of this action and such interest as may be allowed by law. Claim for Relief Under 42 USC 1981 (Defendant Smith) 93. Plaintiff re-alleges and incorporates by reference the preceding paragraphs as if fully set forth herein. 23

24 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 24 of At all times relevant hereto, WSSU and Dr. Janice Smith had final policy making authority and/or decision making authority in connection with the discriminatory employment actions and harassment suffered by the Plaintiff and/or themselves or through their agents and servants engaged in intentional discriminatory conduct against the Plaintiff due to her race (White/Caucasian) in contravention of 42 U.S.C Defendant Smith has discriminated against the Plaintiff based on her race (Caucasian/White) and has deprived Plaintiff of her right to make and enforce contracts guaranteed by the Civil Rights Act of 1866, 42 U.S.C for discriminatory reasons. Defendant Smith did unjustifiably and without good cause take actions adverse to the Plaintiff in the manner described in the factual portion of this complaint set out in paragraphs The aforementioned conduct by Defendant Smith was taken under color of State Law and directly and proximately caused the deprivation of Plaintiff s federally protected rights pursuant to 42 U.S.C As a direct, proximate result of the aforementioned conduct, Plaintiff has been damaged in an amount in excess of $10,000 such damages including: a. Plaintiff was denied reappointment in 2010 based on the conduct of Defendant Smith, b. Plaintiff has lost credibility and has suffered grave injury to her reputation among her colleagues at Winston Salem State University based on the conduct of Defendant Smith, 24

25 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 25 of 30 c. Plaintiff has been passed over for pay raises and job promotions based on the conduct of Defendant Smith, d. Plaintiff has had her chances at securing tenure and senior faculty status irreparably harmed based on the conduct of Defendant Smith, e. Plaintiff s Human Resource Management Degree program has been eliminated in order to justify her removal from employment. f. The Plaintiff s reputation and marketability with another University have been irreparably harmed by the conduct of Defendant Smith. g. Plaintiff has suffered grave emotional and physical injury for which she has been treated by a medical professional as a result of the continued bullying and harassment of Defendant Smith. Plaintiff has suffered from extreme anxiety, depression and physical exhaustion as a result of the conduct of Defendant Smith. h. Additionally, the Plaintiff was pregnant during a large part of Defendant Smith s conduct. Her son was born premature as a result of an emergency C-Section. The Plaintiff s OB-GYN has informed her that the Plaintiff s admission into the hospital, pregnancy complications, and the subsequent premature birth of her child were proximately caused by her physical response to the anxiety and stress caused by Defendant Smith. Claim for Relief Under 42 USC 1983 (Defendant Smith) 98. Plaintiff re-alleges and incorporates by reference the preceding paragraphs as if fully set forth herein. 25

26 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 26 of U.S.C provides that every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory, subjects, or causes to be subjected, any citizen of the United States to the deprivation of any rights, privileges or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceedings for redress Defendant Smith has deprived Plaintiff of her right to be free of racial discrimination as secured by the Constitution of the United States, including 42 USC Section 1981, as amended Such deprivation has caused Plaintiff to suffer injury and damage and Defendant Smith is liable to Plaintiff in this suit, for all injuries and damages so caused Pursuant to 28 U.S.C. 1343(a)(3), this Court has jurisdiction to redress the deprivation of Plaintiff s rights By reason of the Defendant Smith s conduct, Plaintiff has suffered actual economic and other compensatory damages in excess of $10, The discrimination by Defendant Smith as set forth herein was purposeful, deliberate, intentional, and done with reckless disregard of the rights of Plaintiff. Plaintiff is entitled to recover punitive damages from Defendants in an amount in excess of $10, Plaintiff is also entitled to injunctive and declaratory relief against Defendants. 26

27 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 27 of 30 Punitive Damages (Defendant Smith) 106. Plaintiff re-alleges and incorporates by reference the preceding paragraphs as if fully set forth herein Pursuant to N.C.G.S. 1D, et. seq., Plaintiff contends that punitive damages are required to punish Defendant Smith for her wrongful acts and to deter Defendant Smith and others from committing similar wrongful acts Defendant Smith did act intentionally, maliciously, willfully, wantonly and in reckless disregard to the rights of Plaintiff by inter alia: a. Viciously, maliciously and aggressively bullying, harassing, defaming, and discriminating against the Plaintiff through the specific actions described in paragraphs of this complaint (herein incorporated by reference as if fully set out anew) Under the circumstances of this case, in determining punitive damages, the Court should consider evidence that relates to the following: a. The reprehensibility of the Defendant s motives and conduct; b. The likelihood at the relevant time of serious harm to Plaintiff; c. The degree of the Defendant s awareness of the probable consequences of their conduct; d. The duration of the Defendants conduct; e. The actual damages suffered by Plaintiff; f. Any concealment by the Defendants of the facts or consequences of their conduct; 27

28 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 28 of 30 g. The existence and frequency of any similar past conduct by the Defendants; h. Whether the Defendant profited by the conduct; i. The Defendant s ability to pay punitive damages as evidenced by their revenues or net worth As a direct, proximate result of the aforesaid wanton, reckless, intentional conduct of the defendant, Plaintiff has been damaged in an amount in excess of $10, in compensatory damages. WHEREFORE, MELISSA J. MANN respectfully requests that this Court: 1. Award Plaintiff Damages for the injuries she sustained as a result of the Defendant WSSU s violations of Title VII of the Civil Rights Act of 1964; 2. Award Plaintiff Damages for the injuries she sustained as a result of the Defendant Smith s violations of 42 U.S.C. 1981; 3. Award Plaintiff Damages for the injuries she sustained as a result of the Defendant Smith s violations of 42 U.S.C. 1983; 4. Award Plaintiff Punitive damages against Defendant Smith to punish and deter Smith from similar instances and behavior in the future; 5. Award Plaintiff damages for being forced to take a different position; being slowed down on her partnership track; moving expenses; and loss of money on the sale of her house; all directly attributable to Plaintiff being forced to take a different position; 28

29 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 29 of Direct WSSU to take all necessary steps to remove any employees who have or are continuing to harass the Plaintiff; 7. Award Plaintiff her costs incurred in this action; and attorney s fees as provided by law; and 8. Award Plaintiff such other and further relief as the Court may deem just and proper. JURY DEMAND PLAINTIFF HEREBY DEMANDS TRIAL BY JURY ON ALL ISSUES SO TRIABLE. This the 18th day of September, s/john C. Vermitsky N.C. Bar No Morrow, Porter Vermitsky, Fowler, and Taylor, PLLC 3890 Vest Mill Road Winston-Salem, NC Phone: (336) Fax: (336) /s/ Mathew E. Flatow NC State Bar No SeiferFlatow, PLLC 2319 Crescent Avenue Charlotte, North Carolina Phone: (704) Fax: (704)

30 Case 1:14-cv WO-JLW Document 35 Filed 09/18/15 Page 30 of 30 CERTIFICATE OF SERVICE I hereby certify that the foregoing PLAINTIFF S AMENDED COMPLAINT was electronically filed on the 18th day of September, 2015 with the Clerk of the Court using the CM/ECF system which will send notification of such filing to counsel for Defendant Winston Salem State University and counsel for Defendant Janice Smith. This is the 18 th day of September, /s/ Mathew E. Flatow N.C. Bar No SeiferFlatow, PLLC 2319 Crescent Avenue Charlotte, NC Phone: (704) Fax: (704)

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