Case 4:21-cv-00686 Document 1 Filed on 03/02/21 in TXSD Page 9 of 82
and permits Plaintiffs to press their private claims in this suit against HCC. Because the College accepts federal grant funding,1 the the College thereby expressly agreed to waive its sovereign immunity to the type of racial discrimination and retaliation claims Plaintiffs assert in this case. See Gruver v. La. Bd. of Supervisors for the La. State Univ. Agric. & Mech. Coll., 959 F.3d 178 (5th Cir. 2020) (governmental entity which accepts federal funds held to have expressly waived sovereign immunity as to discrimination claims).
98.
Venue is proper in the Southern District of Texas because the events complained
about in this case substantially occurred in Harris County, Texas, and within the Houston Division. Additionally, the Defendant has its principal place of business in this District. At least one or more of the Plaintiffs have satisfied all conditions precedent, either individually and/or representatively on behalf of the Putative Plaintiff Class, to bring the claims asserted in this suit, including exhaustion of pre-trial administrative opportunities to resolve this dispute, if any such acts were required. IV. BACKGROUND 99.
Plaintiffs are victims of a well-developed, systematic, entrenched, and wildly
successful campaign of deliberate race and sex discrimination against non-Hispanic Black employees in various employee and leadership positions at HCC. This “campaign,” led by Maldonado and implemented and enforced by a number of unsued supervisors at the College, is and was carried out with great efficiency and has resulted in the dismissal, demotion, displacement, and/or termination of Black employees at alarming and disproportionate rates. Maldonado and his henchmen target Black executives and employees to be removed or demoted, then subordinates
1
See Exhibit 1: Relevant pages from the HCC’s 2019 Fund Report documenting its receipt and acceptance of federal funding at the College. Such receipt of federal funds continued throughout the entirety of the period covered by this suit.
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