Original Complaint and Jury Demand
SMU responded harshly
as Davis feared
and ultimately terminated her employment on or about September 12, 2012 because of
her reports. SMU’s retaliation inflicted substantial harm on
Davis, and she now seeks to restore her reputation, to obtain injunctive relief, and to be madewhole.
PARTIES, JURISDICTION, AND VENUE
2. Davis is a female citizen of Richardson, Dallas County, Texas.3. SMU is a Texas nonprofit corporation that conducted business in Texas at all
times material to Davis’s claims by, among others, employing Davis and others in Texas. The
causes of action asserted below arose from and are connected to purposeful acts by SMU during
Davis’s employment in Texas. SMU may be served with process through
its registered agent,Paul J. Ward, Perkins Administration Building, 6425 Boaz, Dallas, Texas 75275.4.
This court has jurisdiction to hear the merits of Davis’s claims under 28 U.S.C. §§
1331 and 1343.5. SMU is located in Dallas, Texas, and a substantial portion of the acts and
omissions underlying Davis’s claims—
including her unlawful termination
occurred in Dallas,Texas. Venue is proper in this district and division under 28 U.S.C. § 1391.
6. SMU is a private institution of higher education founded in 1911 in Dallas, Texas.Each year SMU enrolls 11,000 graduate and undergraduate students in seven colleges (Law,Theology, Art, Business, Education, Engineering, and Humanities and Sciences). Only 31 percent of SMU full-time-faculty was female as of 2012. Of 368 tenured faculty members, only27 percent are women. Women faculty at the highest rank (full professor) earn on average$6,500 less than their male counterparts. Women at the lowest tenure-eligible rank earn an
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