PLAINTIFF’S ORIGINAL PETITION Page 1

CAUSE NO. __________________

ALECIAH JACKSON

v.

CITY OF DALLAS, TEXAS
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IN THE DISTRICT COURT

______JUDICIAL DISTRICT

DALLAS COUNTY, TEXAS


PLAINTIFF’S ORIGINAL PETITION

TO THE HONORABLE JUDGE OF SAID COURT:

Plaintiff Aleciah Jackson files this, her Original Complaint and prayer for relief against
Defendant City of Dallas and in support would show the Court as follows:
PARTIES
1. Plaintiff Aleciah Jackson is a resident of Rockwall County, Texas and a sworn
officer of the Dallas Police Department and an employee of the City of Dallas, Texas.
2. Defendant City of Dallas, Texas is a municipality of the State of Texas and may
be served with process by serving Rosa A. Rios, City Secretary, City of Dallas, Dallas City Hall,
1500 Marilla Street, Room 5D South, Dallas, Texas 75201-6390.
VENUE
3. Venue in this Court pursuant to Tex. Civ. Prac. & Rem. Code § 15.002(a)(1) as
Dallas County is the county in which all or a substantial part of the events or omissions giving
rise to the claims occurred.
DISCOVERY LEVEL
4. Plaintiff files this suit as a Discovery Level 2 suit as set forth in Texas Rule of
Civil Procedure 190.3.
DC-14-08242
Freeney Anita
FILED
DALLAS COUNTY
7/31/2014 3:07:59 PM
GARY FITZSIMMONS
DISTRICT CLERK

PLAINTIFF’S ORIGINAL PETITION Page 2
REQUEST FOR DISCLOSURE
5. Pursuant to Rule 194, Defendant is requested to disclose, within fifty days of
service of the Petition and Request, the information and material discussed in Rule 194.2(a)-(l)
of the Texas Rules of Civil Procedure.
FACTS
6. Plaintiff Aleciah Jackson has timely met all conditions to filing this suit. Plaintiff
dual-filed a charge of Discrimination on the basis of Defendant’s retaliatory actions for her
participation in a protected activity of providing notice of and complaints regarding a hostile
work environment arising from a co-worker’s sexual conduct and racially discriminatory conduct
in the workplace. This charge was submitted to the Equal Employment Opportunity
Commission (“EEOC”) and the Texas Workforce Commission (“TWC”) on May 12, 2014.
Rather than investigate, the EEOC investigator Juan F. Munoz immediately issued a Dismissal
and Notice of Rights.
7. Aleciah Jackson is a sworn officer with Dallas Police Department (“DPD”) and
has been an officer since May 24, 1989 and has served continuously without any material
disciplinary issue or complaint. Ms. Jackson has held the rank of Senior Corporal since 2002.
8. From the year 2008 to November 17, 2013 Sr. Corporal Jackson was assigned to
the Personnel Division of the Dallas Police Department where, as part of her job responsibilities
she performed background investigations for officer recruits and civilians seeking employment
with the Dallas Police Department and assisted with other aspects of the interview and
application process. These duties and responsibilities entitled Sr. Corporal Jackson to receive
additional compensation, Detective’s pay.

PLAINTIFF’S ORIGINAL PETITION Page 3
9. The Personnel Division to which Sr. Corporal was assigned is a relatively small
unit, requiring approximately 24 officers to work closely together and coordinate their daily tasks
and routines. In November 2012 a female officer was added to the division who quickly became
a disruptive force. Over the one (1) year time period this officer began having sexual and
romantic relationships with male officers in the division. In addition to her sexual relationship
with male officers in the division, this female officer openly flirted with her supervising
Sergeant. This female officer created a sexual charged environment which through the use of her
relationships she received preferential assignments and was not required to perform or was
released from the less desirable assignments. This female officer was allowed to avoid work and
performed what duties she wanted when she wanted.
10. This officer then created such a hostile and disruptive environment that male
officers in the unit began threatening each other. This female officer then began to make
multiple allegations of sexual harassment against African American males in the division. She
also advised her superiors that she did not like working with female African American officers,
such as Sr. Corporal Jackson and would report them to supervisors alleging that they “talked
about her” or were rude, resulting in the African American officers being reassigned in their
duties and physically removed from their assignments. Rather than counsel the officer or
discipline her for her racist comments and refusal to work with female African American
officers, Plaintiff and the other officers had their schedules and assignments changed to
accommodate the disruptive officer.
11. The environment became so poisonous and this female officer’s influence was so
pervasive that it impeded the Plaintiff’s ability to perform her duties on a daily basis. Plaintiff
made numerous complaints to her supervisors, and considered filing a complaint with DPD’s

PLAINTIFF’S ORIGINAL PETITION Page 4
Internal Affairs Department (“IAD”), the only avenue left to address the work conditions caused
by the discriminatory actions and sexual conduct of the other female officer.
12. In frustration, Sr. Corporal Jackson went outside her chain of command to speak
with Chief Cynthia Villarreal with whom she had worked in the past. On a Tuesday night,
November 12, 2013, Sr. Corporal Jackson had a long telephone conversation with Chief
outlining the problems in the Personnel Division which the other female officer had caused.
Plaintiff was seeking the Chief’s advice and told the Chief she was considering filing a
complaint with IAD. The Chief told Plaintiff she should not file a complaint, to “keep her head
low” and let the other officer “burn her bridges.” Chief Villarreal said she would look into the
matter.
13. Just three (3) days later, on November 15, 2013, Plaintiff was notified she would
be removed from Personnel Division and transferred to patrol, resulting in a loss of her
Detective’s pay. The department representatives refused to give a reason for this detrimental
transfer. While Plaintiff was transferred, several officers who were involved with the offending
female officer or supervised her were left in the division.
COUNT ONE: VIOLATION OF TEXAS LABOR CODE § 21.055
14. Defendant employs at least fifteen (15) employees within the meaning of the
Texas Labor Code and is an employer as defined by Tex. Labor Code § 21.002.
15. Defendant City of Dallas violated the Texas Labor Code § 21.055 by taking a
tangible employment action against Plaintiff because she complained of and opposed what she
reasonably believed to be a racially discriminatory and sexually hostile workplace caused by the
conduct of a co-worker. Specifically, Plaintiff was transferred as a result of her complaints to

PLAINTIFF’S ORIGINAL PETITION Page 5
her supervisors and ultimately to Chief Villarreal and her expressed desire to make a formal
complaint to IAD.
16. Plaintiff is entitled to recover damages from Defendant for lost back pay since her
transfer, reinstatement to her previous position, front pay and other pecuniary losses. In addition
Plaintiff is entitled to recover compensatory damages arising from her transfer.
COUNT TWO: TITLE VII - RETALIATION
17. Defendant is an employer as defined by Title VII of the Civil Rights Act of 1964,
as amended.
18. Sr. Corporal Jackson, by her complaints to her supervisors and discussions with
Chief Villarreal engaged in a protected activity as defined by Title VII, 42 U.S.C. 2000e-3.
19. Subsequent to her conversation with Chief Villarreal and her express desire to
initiate a formal complaint process, Defendant retaliated against Plaintiff by transferring her back
to patrol, a less desirable position, removing her from a position in which she had developed
particular expertise over her four (4) years in the division. The result was a decrease in her
compensation by removing her ability to collect Detective’s pay.
20. Defendant City of Dallas violated Title VII by taking a tangible employment
action against Plaintiff because she complained of and opposed what she reasonably believed to
be a racially discriminatory and sexually hostile workplace caused by the conduct of a co-
worker. Specifically, Plaintiff was transferred as a result of her complaints to her supervisors
and ultimately to Chief Villarreal and her expressed desire to make a formal complaint to IAD.
21. Plaintiff is entitled to recover damages from Defendant for lost back pay since her
transfer, reinstatement to her previous position, front pay and other pecuniary losses. In addition
Plaintiff is entitled to recover compensatory damages arising from her transfer.

PLAINTIFF’S ORIGINAL PETITION Page 6
ATTORNEY FEES
22. As a consequence of the above described facts, and in the furtherance of
Sr. Corporal Jackson’s rights, duties and obligations with respect to her employment it was
necessary for Plaintiff to retain the undersigned attorneys. Plaintiff hereby seeks to recover for
all reasonable and necessary attorneys’ fees and costs incurred in enforcing said rights and
duties.
STATEMENT OF RELIEF UNDER RULE 47
23. Plaintiff Aleciah Jackson seeks monetary relief over $100,000 but not more than
$500,000, including damages of any kind, penalties costs, expenses, pre-judgment interest and
attorney fees.
JURY DEMAND
24. Plaintiff hereby demands a jury trial.
WHEREFORE, for the reasons stated above, Plaintiff respectfully requests that
Defendant City of Dallas be cited to appear and answer, and that on final trial of this matter,
Plaintiff receive the following:
a. Entry of Judgment in her favor and against Defendant for actual damages,
including pecuniary damages, back pay, front pay and compensatory damages;
b. Reinstatement to her position in the Dallas Police Department Personnel Division,
along with reinstatement to a position in which she is entitled to Detective’s pay;
c. All reasonable and necessary attorneys’ fees;
d. All costs of suit; and
e. Such other and further relief to which Plaintiff may be justly entitled, both at law
and in equity, whether specific or general.

PLAINTIFF’S ORIGINAL PETITION Page 7
Respectfully submitted,

BELLINGER & SUBERG, L.L.P.

By:
BARBARA L. EMERSON
State Bar No. 06599400
HAAKON T. DONNELLY
State Bar No. 24032133
10,000 N. Central Expy., Suite 900
Dallas, Texas 75231
Telephone: 214/954-9540
Facsimile: 214/954-9541
bemerson@bd-law.com
hdonnelly@bd-law.com

ATTORNEYS FOR PLAINTIFF
ALECIAH JACKSON



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