Case 4:21-cv-00686 Document 1 Filed on 03/02/21 in TXSD Page 67 of 82
certifications to perform her duties well and above reproach. Nevertheless, similar to other Black police officers employed at HCC, she is severely underpaid for the same position and duties that other White and Hispanic officers are paid. Specifically, a Hispanic officer with similar qualifications to Ms. Wallace was hired around the same time. The Hispanic officer, Jennifer Montieo, was onboarded with a starting salary of nearly $10,000 more than Ms. Wallace. More alarming, Ms. Wallace was forced to patrol HCC without all of the necessary equipment required by an officer to do their job safely and effectively. She was not provided with a taser until December 2019, only after a more senior Black officer forced the department to issue her one. No reason was ever provided to Ms. Wallace as to why she would be endangered this way. Ms. Wallace and other similarly situated Black officers at HCC have continuously brought the pay disparity issue to their supervisors’ and HR's attention. To date, no action has been taken by HCC to ensure that these dedicated officers are paid equal or comparable to their White and Hispanic counterparts. Ms. Wallace has continued to be intimidated and abused by her superiors and faced unwarranted disciplinary actions. Regarding the present lawsuit, Ms. Wallace and other Black police officers have been threatened with termination if they participated in this lawsuit by their supervisors. 202.
Germaine Washington - Ms. Washington has worked at HCC as a Manager of
Conference Services for the last five (5) years. She has been refused the title and compensation paid to directors even though she handles and performs the duties of a director. Even when a recent directorship opened up, she was told by her supervisor that she would not be allowed to assume the position even though she was the best qualified and already doing the work of the director. In addition, instead of bestowing on her the title for the job functions she was performing, she was told that HCC would be willing to pay her a stipend for the work, but not bestow on her the title.
Page 67 of 82
