UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION


VICTORIA BRIDGEFORTH, )
Plaintiff, ) Case No.: 14-Cv-
)
v. ) Honorable
THOMAS J. DART, SHERIFF OF COOK )
COUNTY, ILLINOIS, and COOK COUNTY ) Magistrate
ILLINOIS, a Municipal Corporation and )
Body Politic )
Defendants. ) Jury demanded


COMPLAINT UNDER TITLE VII OF CIVIL RIGHTS ACT OF 1964 (UNLAWFUL
EMPLOYMENT DISCRIMINATION AND HARASSMENT BASED ON SEX )

Plaintiff complains of the Defendants as follows:

Count I Sex Discrimination and Harassment in Employment

1. Jurisdiction of this case is based upon Federal question, as Plaintiff claims

redress for unlawful employment discrimination based upon sex under Title VII of the Civil

Rights Act of 1964, Title 42 USC Section 2000e et seq.

2. Venue is proper in this Court as the cause of action arose and all acts complained

of herein transpired in the County of Cook, State of Illinois, within the geographic expanse of

this Court.

3. At all times relevant to this Complaint, Plaintiff Officer VICTORIA

BRIDGEFORTH was and remains a Deputy Sheriff of Cook County, employed by Defendant

Sheriff Thomas J. Dart (Dart) within the Cook County Sheriffs Department and Cook County

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Department of Corrections (CCDOC). Plaintiff has been employed by CCDOC, within the

Cook County Jail (Jail), at all times since October 7, 2005.

4. Plaintiff is a female member of the Black or African-American race.

5. At all times Plaintiffs job performance has met the legitimate expectations and

requirements of her job at CCDOC. Plaintiffs job performance has in fact consistently exceeded

the legitimate expectations and requirements of her job at CCDOC.

6. In March 5, 2013 through and after April, 2013, supervisory personnel within

CCDOC, in particular Sergeant Windmon, harassed Plaintiff, subjected her to differential

treatment, imposed discipline against Plaintiff based upon fabricated or knowingly false

allegations of misconduct, physically struck Plaintiff and abused and intimidated Plaintiff

unlawfully based upon her sex, female.

7. Plaintiff was employed by Respondent working the 6:00pm to 2:00p.m. (Day)

shift from March through May, 2013.

8. At that time, Sergeant Windmon, a supervisory employee employed by Dart and

CCDOC as a Correctional Sergeant, worked the 11:00pm to 7:00a.m. (Midnight) shift, in the

same Division of the Jail as Plaintiff.

9. Sergeant Windmon at that time began making false charges and claims of

misconduct and rules violations against and imputed to Plaintiff. Plaintiff was forced to file

grievances and defend herself against such spurious and false charges and accusations.

10. Sergeant Windmon also physically struck Plaintiff, on about March 20, 2013,

without cause or provocation attributable to the Plaintiff.

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11. Sergeant Windmon later stuck out her tongue at Plaintiff, and recited a

spiritless apology for having earlier struck Plaintiff.

12. Certain other supervisory employees of CCDOC and Defendant Dart received this

information but failed promptly to act upon it.

13. When CCDOC Commander Hall received the Incident Report concerning the

striking incident of March 20, 2013, he denied it, and removed the video surveillance tape and

media so as to cover up the incident or otherwise to impede the investigation of the incident, as

reported by Plaintiff, and to prevent detection of Sergeant Windmon as the perpetrator of the

physical striking.

14. Similarly, Defendant Darts designated Union representative, upon information

and belief, failed to devise a viable strategy for responding to this striking incident. No action

was taken of which Plaintiff is aware to reprimand or discipline Sergeant Windmon or to stop

harassment of Plaintiff and protect Plaintiff.

15. Lieutenant Blount, a CCDOC supervisory employee, also learned of the

harassment of Plaintiff by Sergeant Windmon, but denied it.

16. These events caused substantial distress to Plaintiff, made Plaintiff afraid of or

resistant to going to work, and by multiple means changed the conditions of Plaintiffs

workplace at CCDOC.

17. Plaintiff at all times during her employment by Defendant Dart and CCDOC has

met and exceeded the legitimate expectations of CCDOC and Dart concerning her employment

and performance as a Corrections Officer.

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14. Defendant Dart and CCDOC additionally failed and refused to furnish to Plaintiff

performance reviews for her work.

15. Similarly situated male officers and deputies, upon information and belief, have

not been subjected to the same abuse, harassment and mistreatment as that to which Plaintiff is

subjected as described hereinabove.

16. Plaintiff is entitled to relief from Defendant Dart and CCDOC, including

rescission and expungement of all unlawful and false reports of discipline or misconduct against

Plaintiff, and payment of and other appropriate remuneration for Plaintiffs damages caused

directly and proximately by Defendant Dart and CCDOC, and its agents, including but not

limited to those designated hereinabove.

17. The acts of Defendants agents as set forth hereinabove directly and proximately

damaged Plaintiff in humiliation, diminution of her reputation and standing among her superiors,

colleagues, and subordinates, emotional distress, mental anguish, tension, anxiety and torment.

18. Plaintiff filed a charge with the Equal Employment Opportunity Commission

(EEOC), No. 440-2014-01918 mailed January 14, 2014 (stamped by EEOC on January 16,

2014). The EEOC issued its Right-To-Sue letter in this Charge on March 18, 2014, and

Plaintiffs counsel received the Right-To-Sue letter on March 20, 2014.

Wherefore, Plaintiff VICTORIA BRIDGEFORTH respectfully requests that she

be awarded judgment in a sum in excess of $75,000.00 against Defendant Sheriff Thomas J.

Dart, Sheriff of Cook County, Illinois, plus attorneys fees, costs and such further relief as the

Court deems just. Plaintiff demands trial by jury.

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Count II Indemnification Claim Against Defendant COOK COUNTY, ILLINOIS,
A Body Politic, under Ch. 745 ILCS Section 10/9-102


19 - 36. Plaintiff repeats the allegations of paragraphs 1 through 18, inclusive, of

Count I as though fully set forth.

37. Defendant Sheriff Thomas J. Dart, Sheriff of Cook County, is an elected official

whose official salary and expenses, as well as all those of the Cook County Sheriffs

Department, are funded entirely by Defendant Cook County, Illinois.

38. Pursuant to Ch. 745 ILCS Section 10/9-102, any liability or judgment adjudicated

and entered against Defendant Sheriff Thomas J. Dart, Sheriff of Cook County would be

indemnified and paid by Defendant Cook County, Illinois.

39. As such, Defendant Cook County, Illinois, a body politic, is a necessary party

defendant to this lawsuit.

Wherefore, Plaintiff VICTORIA BRIDGEFORTH respectfully requests that she be

awarded judgment in a sum in excess of $75,000.00 against Defendants Cook County, Illinois, a

body politic, indemnor of Sheriff Thomas J. Dart, Sheriff of Cook County, Illinois, jointly and

severally, plus attorneys fees, costs and such further relief as the Court deems just.


Victoria Bridgeforth,
Michael J. Greco. Attorney at Law
Attorney for Plaintiff
175 W. Jackson Blvd., Suite 1600
Chicago, Illinois 60604
(312) 222-0599 By:__/S/_ Michael J. Greco ___________
Atty. No. 06201254 Michael J. Greco
Attorney for Plaintiff

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