Several Board members made derogatory statements questioning his loyalty to theUnited States.
Failing and refusing, and continuing to fail and refuse, to hire plaintiff and hisclass because of his race;
These allegations were false, but the publicizing of the accusation on the 10pm news hasembarrassed and humiliated plaintiff and has and will impair the plaintiff’s ability tosecure future employment.
On ___, 2008, defendant terminated plaintiff from his position of personal director for theVillage of West Moravia.
Defendant did not give plaintiff an opportunity to rebut the charges that he had stolen atire and that he behaved rudely to the residents of West Moravia.
• Plaintiff as aggrieved employee/member of a protected class
Plaintiff is an Arabic male, was hired by Defendant to work as a (position description) in its(office name), located in (name of city and state) during the period of 2005-2010, when he wasterminated effective ___, 2008.
• Statutory provision violated.
These acts violate Title VII of the Civil Rights Act of 1964.
Other Factors to consider under Title VII
oHe is qualified to do his job.oNo intent requirement for discrimination required.oAn inference can lead to a violation of the statute.
• Timely filing of charge by employee with, or referral by Equal Employment OpportunityCommission (EEOC) of charge filed by member to, state or local agency authorized to act.
I don’t know if we have this information yet!
2) Checklist for Violation of 42 U.S.C.A. s. 1983
• Plaintiff's standing and capacity to sue, if required. See above.• Acts of defendant resulting in violation of plaintiff's civil rights, and illegality of those acts. Seeabove.• Defendant as employer, employment agency, or labor organization within meaning of Act.State actor is Village of West Moravia.• Whether state or local agency authorized to act; Allegation that the conduct alleged wasengaged in under color of state law, and that such conduct subjected plaintiff to the deprivation