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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. CLAUDIA MITCHELL, Plaintiff, v. RICARDO FLORES MAGN ACADEMY, INC., a Colorado nonprofit corporation and public charter school, and MARCOS MARTNEZ, in his individual capacity, Defendants.

COMPLAINT

Plaintiff, Claudia Mitchell, by and through her attorneys, Sweeney & Bechtold, LLC, hereby submits her Complaint against the above-named Defendants as follows:

I. INTRODUCTION 1. Plaintiff Mitchell worked for Defendant Ricardo Flores Magn Academy, Inc.

(RFMA) as an associate teacher between August 12, 2009 and November 30, 2009. She was terminated after she was hospitalized with complications resulting from the H1N1 virus. Plaintiff Mitchell brings this action pursuant to the Americans with Disabilities Act, as amended (ADA), Title VII of the Civil Rights Act of 1964, as amended (Title VII). 42 U.S.C. 1981, 42 U.S.C. 1983, and state common law.

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II. JURISDICTION AND VENUE 2. Jurisdiction is proper in this Court pursuant to 28 U.S.C. 1331 and 1343, in

that this action arises under federal law, specifically the ADA, Title VII, 42 U.S.C. 1981, and 42 U.S.C. 1983. This Court has jurisdiction over Plaintiffs supplemental state law claims pursuant to 28 U.S.C. 1367. 3. Venue is proper in this judicial district pursuant to 28 U.S.C. 1391(b), as the

unlawful employment practices alleged herein were committed within this judicial district. 4. The procedural prerequisites for the filing of this suit have been met. Plaintiff

Mitchell filed a charge of discrimination with the EEOC on March 12, 2010. She also filed an appropriate Notice of Claim under Colorados Governmental Immunity Act on March 16, 2010.

III. PARTIES 5. Plaintiff Claudia Mitchell is a resident of the State of Colorado and was an

employee of RFMA between August 12, 2009 and November 30, 2009. 6. Defendant RFMA is a Colorado nonprofit corporation and public charter school

licensed to do business in the State of Colorado. Defendant RFMA had more than 15 employees during the relevant time period. 7. Defendant Marcos Martnez is a resident of the State of Colorado. He is and was

RFMAs Head of School during the relevant time period.

IV. GENERAL ALLEGATIONS 8. Plaintiff Mitchell began working for RFMA as an associate teacher for first and 2

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second graders, and one third grader on August 12, 2009. 9. Defendant RFMA is a public charter school, with approximately 200 students

from Kindergarten to 4th grade. 10. Although Plaintiff Mitchell is Hispanic, she is married to a Caucasian and legally

uses her husbands last name. 11. From the outset, this fact was a problem from the schools perspective. For

example, during her job interview, Defendant Martnez specifically asked Plaintiff Mitchell what she would tell her students when they asked why are you married to a white man? Plaintiff Mitchell was understandably offended by this racist question. 12. In addition to this comment, Mr. Martnez has stated we dont need Anglo

teachers teaching our kids, referring to the predominantly Hispanic students. White teachers were only hired in situations where there were no qualified Hispanic teachers available for the positions. 13. Defendant Martnez was so strongly prejudiced against hiring Anglo employees at

RFMA that he did not want Hispanic teachers with Anglo surnames to use their last names. He would instead tell them to go by their Hispanic maiden names or by the first initial of their Anglo surnames. 14. In Plaintiff Mitchells case, Defendant Martnez told her that We are going to

call you Mrs. M., and she was given no choice in the matter. One female employee refused Defendant Martnezs demand, and instead went by her Anglo married name. She was terminated approximately six months later, allegedly because she wasnt happy at RFMA. 3

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15.

Defendant Martnez was so adamant about erasing any evidence of non-Hispanic

ethnicity from the school that he would not allow teachers to display the American flag in their classrooms, unless there were going to be outside visitors to the school. In addition, students were not allowed to say the pledge of allegiance, and they were not taught other mainstream facts of American history in violation of Defendant RFMAs Charter School Contract and Colorado law. 16. Besides being denied the right to use her legal last name, Plaintiff Mitchell was

denied training afforded to employees with Hispanic surnames. For example, during her interview, both Defendant Martnez and Mr. Vigil promised to mentor Plaintiff Mitchell and to help her with the curriculum since they knew that this was her first teaching assignment. However, this never occurred. Although Mr. Vigil mentored two teachers with Hispanic surnames on a daily basis, he could not even take the time to go through Plaintiffs November evaluation with her. In fact, after Plaintiff observed Mr. Vigil teaching her class on the first day, he left her to do the lessons and planning, and consistently told her that he did not have the time to mentor her. 17. During her employment with Defendant RFMA, Plaintiff Mitchell was never

provided with any employee handbooks or a written absenteeism policy. Instead, when Plaintiff Mitchell asked about the protocol she should follow if she needed to take time off, both Defendant Martnez and Antonio Vigil simply told her to please give us 72 hours notice if you can, when you know you will be out for sickness, doctors appointments, etc. 18. Prior to her termination, Plaintiff Mitchell had only missed two days and

approximately four hours of work, and she was never told that her absences were excessive.

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19.

In the employee handbook which was in effect through at least the 2008-2009

academic year, regular full-time employees were entitled to three days of paid personal leave per academic year. They were also entitled to five days of paid sick leave, as well as an unpaid medical leave of absence for a period of up to one month, which could be extended with the approval of the Head of School on a month-to-month basis for a maximum of three months, for those full-time employees, such as Plaintiff Mitchell, who had completed at least ninety days of continuous employment. 20. Plaintiff Mitchell suffers from a disability (asthma), which substantially limits her

ability to breathe and her pulmonary functioning. In fact, if she does not take daily medication for her disability, it would be impossible for her to breathe at all. Plaintiff Mitchells disability also leaves her vulnerable to severe pulmonary infections, including bronchitis and pneumonia. 21. On November 23, 2009, Plaintiff Mitchell was exposed to a student from Mexico

with an extremely high temperature and other symptoms of the H1N1 virus. 22. Even though it was well known that the H1N1 virus had initially spread to the

U.S. from Mexico, and that many of the students at RFMA were from Mexico, the staff never received any H1N1 training, even when the administrators knew that there had already been numerous cases of H1N1 flu in the school since September of 2009. 23. Despite the fact that it had been widely publicized that the H1N1 virus could

prove deadly to children and adults with underlying health conditions, such as asthma, both Defendant Martnez and Mr. Vigil insisted on leaving this child in Plaintiffs classroom with a loose-fitting mask (which she removed while eating lunch). 24. When Plaintiff Mitchell told Defendant Martnez and Mr. Vigil that her immune

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system was already compromised by bronchitis at the time and that she could end up missing work for months if she became ill, Defendant Martnez said that he did not care. Both he and Mr. Vigil said that it was the responsibility of teachers to keep sick kids in the classroom since there was no one and no other place for sick children to be cared for at the school, which violated RFMAs Charter School Contract. 25. Within a matter of days, Plaintiff Mitchell came down with the H1N1 virus, and

informed both Defendant Martnez and Mr. Vigil that she would need to miss work in order to protect her own health as well as the health of her students. Indeed, RFMAs own Instructional Planning Guide obligated Plaintiff Mitchell to do what was necessary to protect the safety, interests, and rights of all individuals in the classroom, or face termination. 26. Previously, the school had easily covered the classrooms of teachers with

Hispanic surnames who needed to miss work for medical reasons. On this occasion, however, Defendant Martnez responded to Plaintiff Mitchells request for accommodation by threatening to dock her pay and terminating her if she did not come in to work sick. 27. Unfortunately, the H1N1 virus made Plaintiff Mitchell so ill due to her underlying

disability that she was hospitalized with pneumonia and breathing complications between November 30 - December 4, 2009. 28. After learning of her hospitalization, Defendant Martnez terminated Plaintiff

Mitchell by placing her on an unpaid leave of absence for the entire 2009-2010 academic year, based only on the false assumption that she would be unable to work for at least two weeks. 29. Other teachers had missed more than two weeks of school in the past for medical

reasons and were not terminated.

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30.

Defendant Martnez claimed that RFMA did not really need Plaintiff Mitchells

position, since the student with H1N1 and her brother were leaving the school. In reality, the departure of two students did not significantly reduce class size, and RFMA replaced Plaintiff Mitchell soon thereafter. 31. Concerned about the health and safety risks existing for both teachers and

students at RFMA, including the schools failure to properly handle suspected and confirmed cases of H1N1, Plaintiff Mitchell filed a complaint with the Tri-County Health Department in December of 2009. Her complaint included allegations that she had been terminated for missing work because she had H1N1, a health condition caused by her disability. 32. Soon thereafter, Plaintiff Mitchell received e-mails from both Defendant Martnez

and Mr. Vigil, placing more onerous conditions on her than other employees before she would be allowed to return to RFMA the following year. For example, Defendant Martnez demanded that Plaintiff Mitchell become highly proficient in speaking Spanish. However, several other teachers at the school (including Defendant Martnez and his brother) were not highly proficient in Spanish, and RFMAs job postings did not require elementary school teachers to be highly proficient in Spanish. 33. Defendant Martnez also required Plaintiff Mitchell to promise that she would not

miss one day of school, especially for the first six months. No other teacher was subject to such a requirement. 34. On January 13, 2010, Plaintiff Mitchell received an e-mail from Defendant

Martnez which said, Wow. You complained about us to the health department . . . wow! And we were seriously going to bring you back. . . . P.S. the visit from the health department went

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great. In reality, the Tri-County Health Department found Defendant RFMA to have committed a number of health and safety violations.

V. STATEMENT OF CLAIMS FIRST CLAIM FOR RELIEF (Disability Discrimination in Violation of the ADA Against Defendant RFMA) 35. Plaintiff hereby incorporates paragraphs 1 through 34 of this Complaint as though

fully alleged herein. 36. At all times relevant herein, Plaintiff was a qualified individual with a disability

under the ADA. 37. Defendant consciously and purposefully discriminated against Plaintiff because of

her disability, in violation of the ADA, in at least the following ways: a. b. failing to reasonably accommodate her disability; threatening to dock her pay if she missed work for reasons related to her disability; c. d. subjecting her to a hostile work environment because of her disability; treating her differently that non-disabled employees with respect to absenteeism; e. effectively terminating Plaintiff by placing her on an unnecessary unpaid leave of absence for the balance of the 2009/2010 school year on November 30, 2009; and f. refusing to rehire Plaintiff for the 2010/2011 school year unless she agreed to conditions not required of non-disabled employees, including the

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condition that she not miss work for reasons related to her disability. 38. As a proximate result of Defendant's actions, Plaintiff has suffered a loss of wages

and benefits, a loss of job, loss of career opportunities and interruption of career path, emotional distress, inconvenience, mental anguish, loss of enjoyment of life and other consequential damages. SECOND CLAIM FOR RELIEF (Retaliation in Violation of the ADA Against Defendant RFMA) 39. Plaintiff hereby incorporates paragraphs 1 through 38 of this Complaint as though

fully alleged herein. 40. By requesting a reasonable accommodation of her disability, Plaintiff Mitchell

exercised her rights under the ADA. 41. Plaintiff Mitchell also exercised her rights under the ADA by opposing practices

made unlawful by the ADA. 42. Defendant consciously and purposely retaliated against Plaintiff Mitchell for

requesting an accommodation of her disability and for opposing practices made unlawful by the ADA, in at least the following ways: a. b. c. d. e. refusing to reasonably accommodate her disability; threatening to dock her pay; subjecting her to a hostile work environment; treating her differently than other employees with respect to absenteeism; effectively terminating Plaintiff by placing her on an unnecessary unpaid leave of absence for the balance of the 2009/2010 school year on November 30, 2009; 9

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f.

refusing to rehire Plaintiff for the 2010/2011 school year unless she agreed to conditions not required of other employees; and

g.

refusing to rehire Plaintiff at all after learning that she had filed a complaint with the Tri-County Health Department, which included allegations that she had been terminated for missing work because she had H1N1, a health condition caused by her disability.

43.

As a proximate result of Defendant's actions, Plaintiff has suffered a loss of wages

and benefits, a loss of job, loss of career opportunities and interruption of career path, emotional distress, inconvenience, mental anguish, loss of enjoyment of life and other consequential damages. THIRD CLAIM FOR RELIEF (Discrimination Based on Racial Association in Violation of Title VII Against Defendant RFMA) 44. Plaintiff hereby incorporates paragraphs 1 through 43 of this Complaint as though

fully alleged herein. 45. Plaintiff Mitchell is Hispanic, and is married to a Caucasian and legally uses her

husbands last name. 46. Defendant consciously and purposefully discriminated against Plaintiff Mitchell

based on her race because of her close association with a Caucasian in violation of Title VII, in at least the following ways: a. unlawfully segregating or classifying Plaintiff Mitchell and other Hispanic employees and applicants for employment who had Anglo surnames, by subjecting them to questioning about their relationships with Caucasians

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during job interviews, and by not allowing them to refer to themselves by their Anglo surnames after being hired by Defendant; b. c. refusing to mentor Plaintiff Mitchell and help her with the curriculum; placing Plaintiff Mitchell on an unnecessary unpaid medical leave of absence for the 2009/2010 school year on November 30, 2009, even though Defendant had covered the classrooms of other teachers with Hispanic surnames who missed work; and d. refusing to hire Plaintiff Mitchell unless she agreed to conditions not required of other teachers with Hispanic surnames. 47. As a proximate result of Defendant's actions, Plaintiff has suffered a loss of wages

and benefits, a loss of job, loss of career opportunities and interruption of career path, emotional distress, inconvenience, mental anguish, loss of enjoyment of life and other consequential damages. FOURTH CLAIM FOR RELIEF (Violation of 42 U.S.C. 1981 Against Both Defendants) 48. Plaintiff hereby incorporates paragraphs 1 through 47 of this Complaint as though

fully alleged herein. 49. Defendants knowingly and willingly engaged in illegal employment practices and

policies which have discriminated against Plaintiff Mitchell because of her race based on her close association with her Caucasian husband. The illegal employment practices and policies to which Plaintiff was subjected include, but are not limited to, the following: a. unlawfully segregating or classifying Plaintiff Mitchell and other Hispanic employees and applicants for employment who had Anglo surnames, by 11

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subjecting them to questioning about their relationships with Caucasians during job interviews, and by not allowing them to refer to themselves by their Anglo surnames after being hired by Defendants; b. c. refusing to mentor Plaintiff Mitchell and help her with the curriculum; placing Plaintiff Mitchell on an unnecessary unpaid medical leave of absence for the 2009/2010 school year on November 30, 2009, even though Defendants had covered the classrooms of other teachers with Hispanic surnames who missed work; and d. refusing to rehire Plaintiff Mitchell unless she agreed to conditions not required of other teachers with Hispanic surnames. 50. The acts or omissions complained of herein were committed under color of law

by governmental officials or agents acting within the scope of their employment. 51. Defendants conduct violated the clearly established rights of Plaintiff Mitchell

which reasonable persons in Defendants position should have known. 52. The aforementioned conduct represented the official custom, policy or practice of

Defendant RFMA. 53. Defendants conduct was engaged in maliciously and with reckless indifference to

Plaintiff Mitchells federally-protected rights. 54. As a proximate result of Defendants actions, Plaintiff has suffered a loss of

wages and benefits, a loss of job, loss of career opportunities and interruption of career path, emotional distress, inconvenience, mental anguish, loss of enjoyment of life and other consequential damages.

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FIFTH CLAIM FOR RELIEF (Abridgment of Freedom of Association Pursuant to the First Amendment of the United States Constitution Against All Defendants) 55. Plaintiff hereby incorporates paragraphs 1 through 54 of this Complaint as though

fully alleged herein. 56. Plaintiff Mitchell exercised her right to freedom of association as afforded by the

First Amendment of the United States Constitution by closely associating with her husband, who is Caucasian. 57. 58. Plaintiff Mitchell was not closely associated by marriage with a Hispanic. Plaintiff Mitchells exercise of her right to freedom of association was a

contributing factor in Defendants retaliatory conduct, including but not limited to the following: a. unlawfully segregating or classifying Plaintiff Mitchell and other Hispanic employees and applicants for employment who had Anglo surnames, by subjecting them to questioning about their relationships with Caucasians during job interviews, and by not allowing them to refer to themselves by their Anglo surnames after being hired by Defendants; b. c. refusing to mentor Plaintiff Mitchell and help her with the curriculum; placing Plaintiff Mitchell on an unnecessary unpaid medical leave of absence for the 2009/2010 school year on November 30, 2009, even though Defendants had covered the classrooms of other teachers with Hispanic surnames who missed work; and d. refusing to hire Plaintiff Mitchell unless she agreed to conditions not required of other teachers with Hispanic surnames.

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59.

The acts or omissions complained of herein were committed under color of law

by governmental officials or agents acting within the scope of their employment. 60. Defendants conduct violated the clearly established rights of Plaintiff Mitchell

which reasonable persons in Defendants position should have known. 61. The aforementioned conduct represented the official custom, policy or practice of

Defendant RFMA. 62. 63. Plaintiff Mitchell occupied a non-policy making position with Defendant RFMA. Defendants conduct was engaged in maliciously and with reckless indifference to

Plaintiff Mitchells federally-protected rights. 64. As a proximate result of Defendants actions, Plaintiff has suffered a loss of

wages and benefits, a loss of job, loss of career opportunities and interruption of career path, emotional distress, inconvenience, mental anguish, loss of enjoyment of life and other consequential damages. SIXTH CLAIM FOR RELIEF (Abridgment of Freedom of Speech Pursuant to the First Amendment of the United States Constitution Against Both Defendants) 65. Plaintiff hereby incorporates paragraphs 1 through 64 of this Complaint as though

fully alleged herein. 66. Plaintiff Mitchell exercised her right to freedom of speech as afforded by the First

Amendment to the United States Constitution by speaking out on matters of public concern, specifically by filing a complaint with the Tri-County Health Department regarding the health and safety risks existing for both teachers and students at RFMA, including the schools failure to properly handle suspected and confirmed cases of H1N1.

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67.

Defendants intentionally and willfully retaliated against Plaintiff Mitchell for

exercising her right to freedom of speech by refusing to rehire Plaintiff Mitchell because she had filed a complaint against Defendant RFMA with the Tri-County Health Department. 68. The acts or omissions complained of herein were committed under color of law

by governmental officials or agents acting within the scope of their employment. 69. Defendants conduct violated the clearly established rights of Plaintiff Mitchell

which reasonable persons in Defendants position should have known. 70. The aforementioned conduct represented the official custom, policy or practice of

Defendant RFMA. 71. Defendants conduct was engaged in maliciously and with reckless indifference to

Plaintiff Mitchells federally-protected rights. 72. As a proximate result of Defendants actions, Plaintiff has suffered a loss of

wages and benefits, a loss of job, loss of career opportunities and interruption of career path, emotional distress, inconvenience, mental anguish, loss of enjoyment of life and other consequential damages. SEVENTH CLAIM FOR RELIEF (Intentional Interference with Contract Against Defendant Martnez) 73. Plaintiff hereby incorporates paragraphs 1 through 72 of this Complaint as though

fully alleged herein. 74. Defendant Martnez was aware of the employment contract between Plaintiff

Mitchell and Defendant RFMA. 75. With such knowledge, Defendant Martnez intentionally and improperly

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interfered with the performance of the employment contract between Plaintiff Mitchell and RFMA by effectively terminating her on November 30, 2009. 76. 77. Defendant Martnezs conduct was wanton, willful and malicious. As a proximate result of Defendants actions, Plaintiff has suffered a loss of

wages and benefits, a loss of job, loss of career opportunities and interruption of career path, emotional distress, inconvenience, mental anguish, loss of enjoyment of life and other consequential damages. EIGHTH CLAIM FOR RELIEF (Intentional Interference with Prospective Business Opportunity Against Defendant Martnez) 78. Plaintiff hereby incorporates Paragraphs 1 through 76 of this Complaint as though

fully alleged herein. 79. Defendant Martnez was aware of the prospective business opportunity that

Plaintiff Mitchell had at RFMA for the 2010/2011 academic year. 80. With such knowledge, Defendant Martnez intentionally and improperly

interfered with this prospective business opportunity that Plaintiff had when he refused to rehire Plaintiff Mitchell at RFMA after learning that she had filed a complaint against RFMA with the Tri-County Health Department. 81. 82. Defendant Martnezs conduct was wanton, willful and malicious. As a proximate result of Defendants actions, Plaintiff has suffered a loss of

wages and benefits, a loss of job, loss of career opportunities and interruption of career path, emotional distress, inconvenience, mental anguish, loss of enjoyment of life and other consequential damages.

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NINTH CLAIM FOR RELIEF (Intentional Infliction of Emotional Distress Against Defendant Martnez) 83. Plaintiff hereby incorporates paragraphs 1 through 82 of this Complaint as though

fully alleged herein. 84. Defendant Martnezs course of conduct towards Plaintiff as described in this

Complaint is so severe in degree that it goes beyond the bounds of decency and is regarded as atrocious and intolerable in a civilized community. 85. Defendant Martnezs acts were extreme and outrageous and were done with the

intent of causing Plaintiff severe emotional distress. 86. 87. Defendant Martnezs conduct was wanton, willful and malicious. As a proximate result of Defendants actions, Plaintiff has suffered a loss of

wages and benefits, a loss of job, loss of career opportunities and interruption of career path, emotional distress, inconvenience, mental anguish, loss of enjoyment of life and other consequential damages. WHEREFORE, Plaintiff Mitchell respectfully requests that this Court enter judgment in her favor and against the Defendants, and Order the following: a. Compensatory damages, including but not limited to those for emotional distress,

inconvenience, mental anguish, and loss of enjoyment of life as allowed by law; b. c. d. Back pay and benefits as allowed by law; Reinstatement or, in the alternative, front pay and benefits; Punitive damages on Plaintiffs Fourth, Fifth and Sixth Claims for Relief against

Defendant Martnez in his individual capacity; e. Injunctive and declaratory relief; 17

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f. g. h. i.

Other appropriate equitable relief; Pre-judgment and post-judgment interest at the highest lawful rate; Attorney and expert witness fees and costs as allowed by law; and Such further relief as justice requires.

PLAINTIFF DEMANDS A JURY TRIAL ON ALL ISSUES SO TRIABLE. Respectfully submitted this 8th day of August, 2011.

SWEENEY & BECHTOLD, LLC

By:

s/ Joan M. Bechtold Joan M. Bechtold 650 S. Cherry St., Ste. 610 Denver, CO 80246 Telephone: (303) 865-3733 Fax: (303) 865-3738 Email: jmbechtold@sweeneybechtold.com ATTORNEYS FOR PLAINTIFF

Plaintiffs address: 5506 Malta Street Denver, CO 80249

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