Case 4:21-cv-00686 Document 1 Filed on 03/02/21 in TXSD Page 17 of 82
worker in the workplace. The report was made to the College’s police department consistent with policy. The Black female was fired for reporting the white female’s threats to the College's police department while the white female was allowed to remain employed. n. 25+ year employed Black female at the College filed a sexual harassment claim with the College against her white supervisor. She was “investigated” and made to remain under the management and supervision of the white male offender. No known corrective or disciplinary action has been undertaken against the white supervisor. o. 11+ year employed Black male properly corrected a white female vendor who was being disrespectful to subordinates in his department. The white female lodged a false claim of sexual harassment against the Black male. The Administration’s investigator told the Black male that he found the white female’s word more credible even though there were multiple witnesses corroborating the Black male’s side of the story and no credible corroborating witnesses for the white female’s story. p. a Black female, after 4+ years of superlative work at the College, was targeted for removal by the Administration and removed from campus, placed on mandatory leave of absence, demanded to admit to a false claim that she created a hostile work environment if she wanted to keep her job—a demand she rejected, retaliated against for reporting the College’s misuse and suspected theft of federal grant dollars, and ultimately replaced by a woefully unqualified Hispanic male.6 114.
In isolation, or in any particular case, the discriminatory program behind HCC’s
Displacement Plan/“Transformation” program might be difficult to decipher. However, when viewed over years of implementation, the commonality and “success” of the discriminatory scheme against Blacks comes into clear view. There are both objective and subjective data proving the College’s disparate and discriminatory treatment of Black employees since Maldonado’s arrival. C. Individual Plaintiff Allegations of Black Plaintiffs 115.
Jeffery Austin - Race Discrimination: Pay Disparity/Promotion/Advancement
6
The Hispanic male who replaced the experienced Black female had zero experience or training in grant compliance even though the College's job description for the position required multiple years of actual experience in grant management and grant compliance. Brown was qualified for the position—the Hispanic male was clearly not. See Exhibit 3.
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