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UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF SOUTH CAROLINA
CHARLESTON DIVISION

Sabrina Renee Morris, ) CASE NO.: 2:10-cv-3072-CWH-BM

Plaintiff, )
)
vs. )
) COMPLAINT
) Jury Trial Requested
The City of Georgetown, County of Georgetown, )
and Lynn Wood Wilson (Individually) )
Defendants. )
_________________________________________ )

JURISDICTION AND PARTIES

ONE: This suit is brought and jurisdiction lies pursuant to the Civil Rights Act of 1964
(Title VII), 42 U.S.C. §2000e et seq.

TWO: All conditions precedent to jurisdiction under § 706 of Title VII, 42 U.S.C.
§2000e-5, have occurred or been complied with.

a. A charge of employment discrimination on basis of sexual harassment,

retaliation and retaliatory discharge was filed by the Plaintiff with U.S.
Equal Employment Opportunity Commission (“EEOC”).

b. Notification of the Right to Sue was received from the U.S. Equal
Employment Opportunity Commission (“EEOC”) on or about October 4,
2010.

c. This Complaint was filed within the 90 days of receipt of the EEOC’s
Notice of the Right to Sue.

THREE: Plaintiff, Sabrina Morris, is a citizen and resident of the State of South Carolina,
and resides in Georgetown County, South Carolina.

FOUR: That venue is proper in this Court, as the Defendants conduct business in this
judicial division, and the unlawful employment practices giving rise to the Plaintiff’s claims
were committed within this judicial division.

FIVE: Defendant City of Georgetown, upon information and belief, a governmental

entity and is organized and doing business in Georgetown County, State of South Carolina.

SIX: Defendant County of Georgetown, upon information and belief, is a governmental

entity and is organized and doing business in Georgetown County, State of South Carolina.
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SEVEN: Defendant Lynn Wood Wilson, is a citizen and resident of the State of South
Carolina and resides in Georgetown County, South Carolina.

EIGHT: Defendants are a "person" within the meaning of §701 Title VII of the Civil
Rights Act of 1964, 42 U.S.C. §2000e.

NINE: Defendants are an industry that affects commerce within the meaning of the Civil
Rights Act of 1964, 42 U.S.C. §2000e.

TEN: That Defendants are an “employer” for the purposes of the Civil Rights Act of
1964, 42 U.S.C. § 2000e, as the Defendants employs fifteen or more employees for each working
day in each of twenty or more calendar weeks in the current or preceding calendar year.

ELEVEN: The parties, matters and all things and matters hereinafter alleged are within
the jurisdiction of the Court.

STATEMENT OF FACTS

TWELVE: In January 2006, the Plaintiff was hired as the Director of the Building and
Planning Department. Throughout the Plaintiff’s employment with the Defendants, the Plaintiff
was an exceptional employee.

THIRTEEN: During the Plaintiff’s employment, she was subjected to sexual harassment,
working in a hostile work environment and intimidation by the Mayor, Defendant Lynn Wood
Wilson. She was subjected to inappropriate and explicit comments, and other sexual comments
and touching. Each time, the Plaintiff instructed him to stop and said that she was being made to
feel uncomfortable.

FOURTEEN: The Plaintiff reported the lewd and inappropriate behavior of the harasser
to her direct supervisor and the Defendant Wilson. The Defendants began treating the Plaintiff
harshly in retaliation for reporting the lewd and inappropriate behavior.

FIFTEEN: Following the Plaintiff’s report of sexual harassment, the Defendants began
retaliating against the Plaintiff by creating a hostile work environment.

SIXTEEN: It was the duty of the Defendants, by and through their agents, servants and/or
employees, to prevent such acts and behavior from occurring and to stop it once the behavior had
been reported by the Plaintiff.

SEVENTEEN: The Plaintiff maintains that she performed the functions of her job in a
satisfactory manner and throughout her employment with the Defendants did not receive any
verbal or written warnings regarding her performance until after she reported the harassment and
notified her employer of the sexual harassment.

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FOR A FIRST CAUSE OF ACTION

VIOLATION OF CIVIL RIGHTS/DISCRIMINATION

EIGHTEEN: The Plaintiff reiterates and realleges each and every allegation as if fully
set forth herein.

NINETEEN: The Defendants as the Plaintiff and the harasser’s employer were wanton,
and intentional in the harassment of the Plaintiff in the following particulars, to wit:

a. In visual, and verbal contact by sexual advances and gestures that were
initiated, maintained, and repeated after being informed by the Plaintiff that
the contact was unwanted;

b. In continually allowing the perpetrator to maintain their presence near the

Plaintiff while at work in an uncomfortable and inappropriate manner;

c. In allowing a hostile work environment to exist to the extent the Plaintiff

could not continue to work in the environment; and

e. That by reason of the aforesaid recklessness, willfulness and wantonness of

the Defendants, the Plaintiff has suffered injuries, both physically and
mentally

TWENTY: That in failing to protect the Plaintiff from sexual harassment, preferential
treatment or retaliation, the Defendants acted with malice or reckless indifference to the federally
protected rights set out under Title VII of Civil Rights Act of 1964, as amended (42 USCS §§
2000e et seq.), the South Carolina Human Affairs Law and the Equal Employment Opportunity
Act.

TWENTY-ONE: The Defendants violated Title VII of Civil Rights Act of 1964, as
amended (42 USCS §§ 2000e et seq.), and the South Carolina Human Affairs Law by allowing
the sexual harassment, hostile work environment and retaliation to exist in the workplace.

TWENTY-TWO: The Defendants’ wrongful actions as set forth aforesaid constituted a

hostile work environment for the Plaintiff. The Defendants violated Title VII of the Civil Rights
Act of 1964, as amended (42 USCS §§ 2000e et seq.), by allowing a hostile work environment to
exist regarding sexual harassment and retaliation in the workplace.

TWENTY-THREE: That the aforesaid conduct of the Defendants, their agents and
servants, violates South Carolina and United States laws against retaliatory discharge and was, in
fact, retaliatory in nature and in violation of Title VII of Civil Rights Act of 1964, as amended
(42 USCS §§ 2000e et seq.).

TWENTY-FOUR: The Plaintiff’s complaints of sexual harassment were a determining

factor in the retaliation, disparate treatment and constructive discharge of the Plaintiff. But for
the Plaintiff’s complaints of sexual harassment and a hostile work environment, she would not
have been terminated.

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TWENTY-FIVE: As a direct and proximate result of the Defendants’ retaliation on the

basis of complaints of sexual harassment in the workplace and a hostile work environment, the
Plaintiff has suffered a loss of wages and benefits.

TWENTY-SIX: The Defendants’ employment discrimination of thr Plaintiff has caused,

continues to cause, and will cause the Plaintiff to suffer substantial damages for pecuniary losses,
embarrassment, humiliation, pain and suffering, mental anguish, loss of enjoyment of life, and
other nonpecuniary losses.

TWENTY-SEVEN: The Plaintiff is entitled to injunctive relief and/or civil damages from
the Defendants as a result of the employment discrimination as alleged above.

TWENTY-EIGHT: Due to the acts of the Defendants, their agents and employees, the
Plaintiff is entitled to injunctive relief and/or civil damages, back wages, plus interest, payment
for lost benefits, and reinstatement of benefits and front pay.

FOR A SECOND CAUSE OF ACTION

RETALIATION

TWENTY-NINE: The Plaintiff repeats and reiterates the foregoing allegations as if

repeated verbatim herein.

THIRTY: That the unjust disciplinary actions and constructive discharge of the
Plaintiff's employment with the Defendants was the response by the Defendant, their agents and
servants, to the Plaintiff's reports and complaints of lewd and inappropriate behavior of her male
co-worker including sexual harassment.

THIRTY-ONE: That the aforesaid conduct of the Defendants, their agents and servants,
violates South Carolina and United States laws against retaliation and was, in fact, retaliatory in
nature, created a hostile work environment and was in violation of Title VII of Civil Rights Act
of 1964, as amended (42 USCS §§ 2000e et seq.).

THIRTY-TWO: As a direct and proximate result of the acts and practices of the
Defendants in retaliating against the Plaintiff, creating a hostile work environment and the
Plaintiff has suffered and continues to suffer from emotional pain and suffering, mental anguish,
humiliation, loss of enjoyment of life, damage to the Plaintiff's reputation and other past and
future losses.

REQUEST FOR RELIEF

THIRTY-THREE: The Plaintiff reiterates and realleges each and every allegation as if
fully set forth herein.

THIRTY-FOUR: Due to the acts of the Defendants, the Plaintiff suffered emotional and
mental distress, fright, revulsion, disgust, humiliation, embarrassment, shock and indignities, lost
wages, loss of front pay, back pay and other work benefits.

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THIRTY-FIVE: That by reason of such wrongful acts of the Defendants, the Plaintiff has
been damaged in such an amount to be determined by the trier of fact.

WHEREFORE, the Plaintiff prays for the following relief:

1. Judgment in favor of the Plaintiff and against the Defendants for all causes of
actions in an amount which is fair, just and reasonable, and for compensatory
damages;

2. Prejudgment interest, costs and attorneys fees as may be allowed by law;

3. Judgment in favor of the Plaintiff and against the Defendants with back pay and
associated benefits she would have earned with all lost or diminished benefits
such date to be determined by the trier of fact;

4. Judgment in favor of the Plaintiff and against the Defendants for front pay and
any other work benefits she lost in an amount to be determined by the trier of fact;

5. Judgment in favor of the Plaintiff and against the Defendants for pain and
suffering, embarrassment and humiliation, and emotional distress in an amount to
be determined by the trier of fact; and

6. Judgment against the Defendants, in such an amount of actual damages, punitive

damages, attorney fees, costs of this action and any other relief this Honorable
Court deems allowable under law, and just and proper.

s/Jarrel L. Wigger
Jarrel L. Wigger, Esquire, Fed. I.D. # 6345
Attorney for the Plaintiff
8086 Rivers Avenue, Ste. A
North Charleston, SC 29406
(843) 553-9800
Charleston, South Carolina
This 2nd day of December, 2010.