Case 3:19-cv-01640-SRU Document 1 Filed 10/17/19 Page 1 of 7

UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT

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LAURA JEAN CHAMPAGNE | CIVIL ACTION NO.:
Plaintiff |
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VS. | JURY TRIAL REQUESTED
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GOODWIN COLLEGE, INC. | OCTOBER 17, 2019
Defendant |
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COMPLAINT

1. The Plaintiff, Laura Jean Champagne, is a resident of Glastonbury, Connecticut.

2. The Defendant, Goodwin College, Inc., is a company organized under the laws of

the State of Connecticut.

3. The Defendant operates Goodwin College, a private institute of higher education

located in East Hartford, Connecticut.

4. Defendant is a recipient of federal funds including, inter alia, federal student

loans, making it subject to Title IX of the Education Amendments of 1972 (“Title IX”), set forth

in 20 U.S.C § 1681, et seq.

5. Plaintiff began working for the Defendant on or about September 4, 2018 as an

Assistant Professor of Mathematics.

6. In the fall 2018 and spring 2019 semesters, Plaintiff had a student in her math

classes with whom she became friendly.

7. Plaintiff and the student met to work on math problems together and would get

lunch or coffee together while doing so.

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8. During one of these get-togethers, the student conveyed to the Plaintiff that

another professor at the school had offered to give her better grades if she became his mistress.

9. The student further told Plaintiff that she had spoken with other female students

who conveyed that they had similar experiences.

10. Plaintiff was shocked and concerned by this information and she implored the

student to share the identity of the professor with her so that she could report the information to

the Defendant.

11. The student adamantly refused to disclose the identity of the professor to the

Plaintiff.

12. Further, the student told the Plaintiff repeatedly that she wished for her identity to

remain confidential and that she did not want it disclosed to anyone else.

13. Following this disclosure, Plaintiff was initially unsure how to respond.

14. On or around May 6, 2019, Plaintiff emailed an administrative employee of the

Defendant, Madison Yates, and asked her who Defendant’s Title IX Coordinator was.

15. Approximately two or three days later Plaintiff attended a professional

development event.

16. During the course of the professional development, Danielle Wilkins, Defendant’s

Provost approached the Plaintiff and asked her why she had emailed Ms. Yates asking who the

Title IX Coordinator was.

17. Ms. Wilkin stated to Plaintiff, “You don’t ask who the Title IX Coordinator is

without having a reason,” or words to that effect.

18. In response to Ms. Wilkin’s inquiry, Plaintiff explained what she had learned

from the student.

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19. Plaintiff stated that she did not know who the professor was, but she was

concerned, based on what she’d been told, that it was a wide-spread issue involving multiple

students.

20. Ms. Wilken expressed concern in response to learning this information from

Plaintiff.

21. The following day, Plaintiff met with Jean McGill, Defendant’s head of Human

Resources. In this meeting, Plaintiff again stated that she was concerned there may be a wide-

spread issue of sexual harassment involving multiple students.

22. In the meeting, Ms. McGill pressed Plaintiff to disclose the name of the student

who had conveyed the information to her and to identify the class name and the semester the

student had taken the class.

23. Plaintiff stated in response that the student had complained to her in confidence

and had expressly requested not to be identified. Plaintiff further expressed that she could not

violate the student’s trust and confidence by revealing her identity.

24. However, Plaintiff offered to reach back out to the student and see if she would be

willing to come forward or share additional details.

25. Plaintiff, at Defendant’s request, did in fact contact the student in order to

ascertain whether she would be willing to be identified. The student adamantly refused and

unambiguously conveyed to Plaintiff that she did not wish to be identified in connection with her

initial complaint concerning her professor’s sexual harassment of her.

26. On June 21, 2019, Ms. McGill emailed the Plaintiff and instructed her to file an

incident report. Plaintiff complied with this request.

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27. On July 3, 2019, Plaintiff met with Ms. Yates, Terry Antoine, a human resources

employee, and Sharon Koch, Defendant’s Director of General Education.

28. During this meeting, Plaintiff was again pressed to reveal the identity of the

student who’d made the complaint to her.

29. Plaintiff again responded that the complaint had been made in confidence and that

she would not violate the student’s trust.

30. Ms. Antoine threatened Plaintiff in response, asking her what the student would

say “if she knew you were going to lose your job,” or words to that effect.

31. Plaintiff responded that a confidential or anonymous complaint was not prohibited

by Defendant’s policies.

32. Plaintiff also suggested that Defendant could still investigate the matter and

attempt to remedy any potential Title IX violations by, for example, providing additional training

on sexual harassment.

33. The Defendant agreed that Plaintiff could be anonymous, but nonetheless

demanded that Plaintiff share the student’s identity—a result Plaintiff continued to refuse.

34. Immediately following Plaintiff having conveyed the aforesaid complaint

concerning sexual harassment, and in response thereto, Defendant terminated Plaintiff’s

employment on or about July 11, 2019.

FIRST COUNT: Retaliation in violation of Title IX, 20 U.S.C § 1681 et seq.

1. The Plaintiff repeats and re-alleges Paragraphs 1 through 34 above as Paragraphs

1 through 34 of this First Count as if fully set forth herein.

35. The Plaintiff made a report of sexual harassment and participated in the same, as

set forth above, which are protected activities under Title IX.

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36. The Defendant retaliated against the Plaintiff based on her having engaged in the

aforesaid conduct by terminating her employment, in violation of Title IX.

37. As a result of the foregoing unlawful conduct of the Defendant, the Plaintiff was

caused to suffer lost wages and other monetary losses.

38. As a further result of the foregoing unlawful conduct of the Defendant, the Plaintiff

was caused to suffer emotional distress.

39. As a further result of the foregoing unlawful conduct of the Defendant, the Plaintiff,

has expended, or will expend, attorney’s fees and costs.

SECOND COUNT: Wrongful Termination in violation of Conn. Gen. Stat. § 31-51q

1. The Plaintiff repeats and re-alleges Paragraphs 1 through 34 above as Paragraphs

1 through 34 of this Second Count as if fully set forth herein.

35. The Plaintiff spoke out as a citizen on a matter of public concern when she raised

concerns about widespread sexual harassment of Defendant’s students, as set forth above.

36. The Defendant terminated the Plaintiff’s employment in violation of Conn. Gen.

Stat. § 31-51q when it terminated the Plaintiff on account of her foregoing exercise of her free

speech rights under United States and Connecticut Constitutions.

37. As a result of the foregoing unlawful conduct of the Defendant, the Plaintiff was

caused to suffer lost wages and other monetary losses.

38. As a further result of the foregoing unlawful conduct of the Defendant, the Plaintiff

was caused to suffer emotional distress.

39. As a further result of the foregoing unlawful conduct of the Defendant, the Plaintiff,

has expended, or will expend, attorney’s fees and costs.

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WHEREFORE, the Plaintiff prays for the following relief:

1. Monetary damages;

2. Punitive damages;

3. Costs and reasonable attorney's fees incurred in connection with this action;

4. Such additional or alternative relief as may appear to the Court to be just and

equitable.

THE PLAINTIFF,
LAURA JEAN CHAMPAGNE

BY: _______________________
Michael J. Reilly (ct28651)
CICCHIELLO & CICCHIELLO, LLP
364 Franklin Avenue
Hartford, CT 06114
Tel: (860) 296-3457
Fax: (860) 296-3457
Email: mreilly@cicchielloesq.com

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UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT

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LAURA JEAN CHAMPAGNE | CIVIL ACTION NO.:
Plaintiff |
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VS. | JURY TRIAL REQUESTED
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GOODWIN COLLEGE, INC. | OCTOBER 17, 2019
Defendant |
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REQUEST FOR A TRIAL BY JURY

Plaintiff hereby requests a trial by jury in this matter.

THE PLAINTIFF,
LAURA JEAN CHAMPAGNE

BY: _______________________
Michael J. Reilly (ct28651)
CICCHIELLO & CICCHIELLO, LLP
364 Franklin Avenue
Hartford, CT 06114
Tel: (860) 296-3457
Fax: (860) 296-3457
Email: mreilly@cicchielloesq.com