complair,ran! I
: )

:Ll;i.ff- *#t?Tss

.*". *thf


n trunrlnm




cl- 4


I Respondents. t

:l_ :\ .-t',. ''i r,- ;tJ i "--'' t,, :;:,:,6 n. J . j_:
,, I -.-:. 4 *

- ' ;,.' *) h) NowcoMES plaintiff, the ToMMy ("plaintiff "Mr. BENNETT or n*4rrrj, sl S
his attorneys, Thomas V. Leverso of the Law offices of Thomas v. Leve*o, and, pursuant to the lllinois Human Rights Act"775ILCS5/1-1 Ol et seq. [Wesr 20tL) and 775 ILCS5/7A-L02(C)[4J,cornplainsas follows of the Defendants, MINBOW pUSH COALITIONf"Rainbow PUSH?, and lllinois Companyand nonprofit organization, and REVEREND SR IESSE IACI(SON, fRev. |acksonJfcollectively,the "Defendants"). In support thereof,Plaintiffallegesthe following PARTIES& VENUE L. At all times material, Mr. Bennettis and individual and resided, at7022 South ShoreDrivg Chicago, Illinois 6A649. 2Rainbow PUSHis a Chicago-base4 lllinois not-for-profit organization,with its headquarterslocated at 930 East 50th Street Chicago IL 60615. (Ex"A", report from the lllinois Secretaryof Sate of this company.) 3. Mr. Bennett was employedwith Rainbow Push from fuly 1.]-,2007through December 23,20A9. This controversy arises from said employment by Defendantof Mr. Bennett, and aforementionedemplo5rment was basedin the City of Chicago, County of Cooh Sate of lllinois. 5. The majority of the actigns,acts,fiansactions,and/or occurrencesdescribed hereinafter occurredin the Countyof Cooh Stateof lllinois.



Mr. Bennett proper$ and timely submitted a complaint to the Illinois Department of Human Rights on fune 1,g, zotl- A copy of this same complaint is attachedhereto as E)c"8".. 7. The lllinois Departrneuton Human Rights failed to file a formal charge with 365 days, despite b"t{tg notified of Defendants' severe default Thus, Mr. Bennett brings this acHonpursuant to his right to sue,which originated after the 365-daymarh copy of the default notification is attachedas Ex."c". AI.TEGATIONS COMITION AI.t COUNTS TO 8. Mr. Bennett met congressmanfesse fackson fr. in 2000 on a cmise. Mr. Bennett started wor}dng for congressmanfesse fackson fr. in 2006 as a Community Volunteer:Coordinatoron his exploratory committee for mayor ofChicago. 9. on or about september 2a06, Mr. Bennett beganworking for sandi |ackson who was running 7a ward alderman,as the volunteer coordinator. Through Jessefackson fr. and sandi fackson,Mr. Bennett met Rev. fackson and started working for Rainbow push coalition on July lJ, za}T as a National Director of CommunityAffairs. LL. As National Director of Community Affairc, Mr. Bennett was in charge of voter registration,volunteer serviceg the prison program,the legal clinic and membership. Mr. Bennetdssexual orientatio& homosexual,was well known at Rainbow Push due to his nationally syndicatedtalk show,',The Tom |oyner Morning Show." Mr. Bennett'sradio personality name is .,ArubaTommy.,, AJmost immediately after Mr. Bennett started, Mr. Bennett experienced discrimination. L4. caroline wiggrns, the Membershipand vorunteer coordinator; went to Rev. facksonto speakwith him and inform him that she did not want to be under his supervisionbecause Bennettis homosexual. Mr. Rev.|ackson moved Ms. wiggins from under Mr. Bennett's supervision and put her under the supervision of the Field Director, Rev. Livingston. Mr. Bennettwas informed of this byRev. Livingston.






Ms. Wiggins told the entire staff that she was glad that she did not have to answer to Mr. Bennett,a homosexualand that Rev.Livingstonwas her boss. Mr. Bennett complained to Rev. Livingston about the transfer. Mr. Bennett met with Rev. LMngqton and he upset about ig but that there was nothing he could do about it becauseit was a decisionthat Rev.fackson had made.Mr. Bennett was instructed by Rpu Livingston that Mr. Bennett should Iearn to workaround Ms.Wiggins.



From that point forwar4 Ms. wiggins would make a limp wrist gesture towards Mr. Bennett whenever Mr. Bennett walked down the hallway. Mr. Bennett understood the limp wrist gesture to mock his sexual orientation: homosexual.


Shortly tlereafter the transfer, on or about 2008, Ms. Wiggins led a prayer during a volunteer meeting and in her prayet heard throughout the office, she state4 "Bind these homosexualspirits that are in the offfice"and "get thesehomosexuals outof here and do i{in fesus'name." When Mr. Bennett overheardthe prayer, Mr. Bennettarosefrom his desk and approachedMs.wiggins, but was intercepted by Felicia McQuitter,who also heard it and instructed Mr. Bennett to leave and avoid confrontation. Willie Duke also heard the prayer. Mr. Bennettwas shockedand humiliated by Ms. Wiggins'prayer and understood it to be directed at him as he was the only openly gay individual in the office at the time

2L. 22.

soon after, Mr. Bennett filed a complaint Rev,Jackson,Rev-Livingston and Human Resources about Ms.Wiggins'discriminatory conducl A few weeks later; Mr. Bennett was at an event and mn into Ms. Wiggins, sister, Bonita Parker, and she sated tltat her sister had joined Rev. Meeks' church and is "saved".It is well lcrown that Rev. Meeks actively preaches againsthomosexuality.


Mr. Bennettwas never approachedby anyonefrom Rainbow Pushregarding his complaints-Mr. Benneftwas never even sent a responseto his complainL To Mr. Bennett'sleowlddge, no investig3tionor action was taken in response to his complaint


Ms. wiggins Ieft soon after Mr. Bennett filed the complainl To datg Mr. Bennett has no lcrowledgeregardingher reasonsfor leaving. As director of the legaf clinic, Mr. Bennett was responsiblefor a organizinga group of referral attorneys who specialized in different types of law practice. The legal clinic took plgceon Mondays.


26. 27.

Mr. Bennett had a large number of people who camein to the legal clinic for legalassistance with, inter alia,expungements criminal charges. of Among the referral a$orneys was an attorney named Tamara Holder. Ms. Holder demandedthat all casesbe refened to her and that she be placed in charge of all attorneys coming into assist with the legal clinic. Ms. Holder instructed Mr. Bennett that she started the clinic, that it was her clinig and that no cases were to be assigned without her approval. Mr. Bennett understood this to msn that Ms. Holder was assigningthe majority of all cases herself and chargingthe indignant clients. to


As Mr. Bennettwas in chargeof the legal clinig he complainedregarding Ms. Holde/s conducL Mr. Bennett received complaints regarding Ms. Holder's Iegal services. Mr. Bennett then received a letter from Rev.fackson stating that Ms. Holder was in charge of the legal clinic After that, Mr. Bennett refusedto organizethe legal clinic Mr. Bennett believe that Ms. Holder was given control over the legal clinic due to sex (female) and orientation fstraightJ, while it was taken awayfrom Mr. Bennett do to his sex fmale) and sexualorientation fhomosexual).


In 200& at the Rainbow Push Coalition all staff planning meeting for the National Convention,Mr. Bennett requesteda LGBTtable and discussion.Mr. Bennettwas told by Rer1.. when Mr. facksonthat it was not part of the agenda. Bennett questionedwhy not Rev.facksoncursedat Mr. Bennettin front of all of the staff. Rev.facksonwas visibly upset duringthe rest of the meeting.


Mr. Bennett worked under the supervision of Rev. Gregory Seal Livingston, the National Field Director for Rainbow Push. Under his supervision Mr.
Bennett exceeded all expectations.


In 200& Reu Livingstonwent on sick le{ve to care for his dyrng mother.

32. 33.

Within six months afterthe death of his mother, Rev.Livingston went on sick leaveto ere forhis dyingfather. During Rev.Livingston's leaves,Mr. Bennett assumedmany of the duties of the National Field Diregtor. Also in 2008, Rev.fessefackson'stravel assistan! ShelleyDavis,resignedand becamethe chief of staff for Congressman Sheila fackson Lee. Mr. Bennett was appointedas Rev.fackson'stravel assistan! under his direct supervision. Mr. Bennett took his orders as travel assistan! directly from the Rev.Jackson. While undertaking many of the duties of the National Field Director, Mr. Bennett was now additionally expected to take over the duties of Shelley Davis,as Rev.fackson'stravel assistanl Mr. Bennettwas informed by Chiefof stafffohn Mitchell that Mr. Bennett was expectedto ake on these additional duties - both for the National Field Director and as Rev. fackson's travel assistanL In 2008, shortly after Mr. Bennett took on the additional role of Rev. fackson's travel assistant, Mr. Bennett complained to Human Resources, Director McKinnon-Prioe, ttrat he was doing the duties of three positions and spendinghis own personalmoney on the road for tips, hotel and car seryices. No action was taken,despitehis complaints.


As Rev.|ackson's travel assistant,Mr. Bennett faced additional disc-rimination due to his sexualorienhtion. Among other things, Mr. Bennettwas subjected to humiliatingasks. It was well known thatrMs. Holder was a mistress of Rev.fackson. As Rev. fackson'stravel assistant Mr. Bennett had been to Ms. Holderrs apartment with Rev. |ackson and luas told to wait in the car while he went into her apartment on severaloccasions, Bennett was instructed by Rev.fackson Mr. to escort Ms. Holder to Rev. fackson's hotel room at the Hilton at chicago O'Hareairport


0n or about November or December2008, Mr. Bennett was accusedby the Chairman of the Boar4 Martin King, of faxing a letter to the |ackson family

from Kinkos at 2 a.m,informing them of the affair between Rev.facksonand Ms.Holder. After Rainbow Pushdid a thorough investigationof the letter; they found out that the letter came from fudge VanessaHobson,who was anottrer mistress ofRev.fackson. 41.. As Rev.|ackson'stavel assistan! Mr. Bennett traveled on all of his business trips around the world. on travel daya Mr. Bennett was insFucted to go to Rev. fackson's house at personallypaci his clothesand cleanout his closel on or about May 2008, at around 4a.m, Mr. Bennett was at the Rev.fackson,s home packing his clothes for a trip to Tanzania. Rev.Jacksonwas not happy with his packing and started screaming 'motherfuckey'' repeatedly. Despite having his visa for Tanzaniaand preparing for the trip, Rev.fackson removed Mr. Bennettfrom the trip. Mr. Bennettwas insffucted by Rev.Jackson duringtrips to do demeaningand demoralizing asks, including but not limited to, escort women to his room after work hours and cleanup his room after sexualintercoursewith women. Mr. Bennett believes he was forced to do these tasks due to his sexual orientation. In New York at the sheraton Hotel on 57s and 7thAvenue, Mr. Bennett was instructed to escort Ms. Holder to Rev.fackson'shotel room. In Las Vegas, Nevad4 at the Winn Hogeland Resort,Mr. Bennett was insfiucted to arrange a massagefor Rev. Jackson. In Haiti, Mr. Bennett was instructed by Rev. to facksonto escorta yourqgwoman his hotel room after hours. 46. In 2008, at the Hilton Hotel at chicago o'Hare Airport, Mr. Bennett was summoned to Rev.jackson's hotel room and insffucted by Rev.|ackson to clean up and pack his things after he had spent the night with Ms. Holder. Rev.Jacksonw:rs flyrngto New York that day. upon arrival in New Yorlr, Mr. Bennett was again summonsto Reu fackson'sroom and he informed by Rev. fackson ttrat he had a rash between his legs. Rev. fackson instructed Mr. Bennettto go to the drugstore to purchasea prescription.




Mr. Bennett picked upthe prescription and brought it back to his room. Rev, fackson was wearing nrhite brief underwear and instructed Mr. Bennett to apply the cream on his inner thigh. Mr. Bennett refused.Rev.|acksonbecame very an$ry and called [{r, Bennetta "little motherfucker."


Another time at the Hitton at ChicagoO'Hare,Mr. Bennett was summonedto Rev. fackson's room at, to take notes. Prior to that, at dinner, Mr. Bennett retrieved Cialis from his room ffrom a small fold over Tiffany's pouch) and brought it to him at dinner. When Mr. Bennett arrived, Rev. |ackson was dressed gnly in his underwear fbriefsJ and a v-neck t-shirr While Mr. Bennett was talking notes, Rev.fackson had an erection and was stroking his penis with his hand in his underwear. Rev.|ackson'sbreathing rate was accelerated. Before Mr. Bennett left, Rev.|ackson stated that white folks took the word "g4f and gavethe word it's own definition. Rev-fackson further stated that he was a real poor child in North Carolinaand his name was first |esse Burns, and then fesse Robinson and then he becamefesse Jackson.Rev.Jacksonstated that he played football and there was a gay high school teacher who took Rev.fackson under his wings and told him that he needededucationto go along with football. Rev.|ackson said "from that gay teacher,I got a good grade, I got to use his car, I got ten dollars and I got my dick sucked."Rev.facksonsaid,"thads not gay,that is surviving." Mr. Bennett understood this to mean that Rev.fackson wanted him to perform oral sex on him. Mr. Bennettleftthe room.


Rev.facksonalso made inappropriate gesturestoward Mr. Bennett in public. When shaking Mr. Bennett's han4 the Rev. Jacksonwould always take his middle finger and rub the middle of Mr. Bennetdshand.


Mr. Bennett complainedto Human Resources that Mr. Bennett was working 60-70 hours per week and doing the job of three separate positions. No action was taken. Mr. Bennett's straight co-workers were not required to do the work of three separatepositions.


Mr. Bennett made Rev. fackson avrare on numerous occasions that Mr. Bennettwas uncomfortablecleaningup his hotel rooms, escortingwomen to


his hotel room, being Summoned his hotel room after hours or packing his to clothes.


In the beginning of X)09, Dexter clinkscale became Rev. fackson's travel assistant During the $pring 2009, Mr. Clinkscalehad a 24 year-old male intern from Texasin his office. In April 2009, Mr. Bennett was on his way to Club Escapeto meet frtends.This intern askedto join becausehe sated that he wanted to go out to a gay bar. Mr. Bennett and the intern met up with Darius Mayfield and Cbrl Grant A month later, the intern stated that Mr. Bennett took him to a gay bar and propositioned him and that they smoked marijuana.


From May 2009 to Deeember2009, Mr. Bennett was on paid leave pending investigation. Mr. Benqett was also made to take a drug tesl The drug test came back negative.The personal director conducted an investigation and determinedthatthe allegationswere nottrue.


Mr. Bennett never received findings of the investigations. The Human ResourcesDirector Mctrfinnon-Price, told Mr. Bennett that the casewas not handled correctly and that she suggestedMr. Bennett return to work


Mr. Bennett believes there was no merit to the allegations and that the investigation was prolonged due to his sexual orientation. In contrast, his complaintswere never investigated.


On or about Decemben23, 2009, Mr. Bennett received a letter stating Mr. Bennettwas being laid-,offdueto lack of funding. Based on knowledge and belief, fohnny Savory, was hired to replace Mr. BennetL Several other additional employees were also hired after Mr. Bennettwas laid off. COUI{T I -SEXUAL HARASSMEITIT



Plaintiff restates and reallegesparagraphs 1-57 and incorporates them by referenceas Paragraph 58.


Mr. Bennett suffered ithe intentional, unwanted discrimination by Rev. fackson and Rainbow! PUSH employees because of his sex and sexual orientationof beinga gaymale.

The harassment was severe glven that the words were derogatory and the actions necessarilyrequired Mr. Bennett to perform unwanted actions that were se>mal nature., in 61. The harassment was also pervasive because it lasted the entire time at RainbowPUSH, from |BIy tl, 2007 through December23, 2009, The harassment negatively affected the terms, conditions or privileges of Mr. Bennett's work environment by permitting the hostile insults to outwardly and directly impact him. The requested actions further humiliated Mr. Bennett,forcing him to perlbrm sexualacts outsidethe scopeof the jobs.



The harassmentwould detrimentally affea a reasonableperson of the same sexand sexualorientation, as was inhibitory in the context of performing the actual functions of both jobs.


Managementlmew about the harassment,or should have known, and did nothing to stop it As stated hereinabove, Rev.facksondirectly harassedMr. Bennettin certain instances. As a direct and proximate result of the sexualharassmentand other actions, Mr. Bennett has suffered damagesfrom loss of employment and emotional, psychiatrictrauma and distresscaused.



specifically, Mr. Bennett has lost his apartrnent, his car, and has paid $600/month in CoBMhealth care benefits.

WHEREFORE, Complainant Tommy Bennett prays this Honorable Court enter judgment for him and againstDefendantsRev.fessefackson,Sr.,and Rainbow PUSHCoalitionfor the following amounts: a $98,300 in back-pay,front-pay and loss of benefits, including but not limited to the COBRA premiums; B. $350,000for emotional distressand punitive damages; and C. Any further relief deemedfair, jus! and equitable. couNT II -INTENTIOilAL TNFUCTIONOF EMOTTONAT DTSTRESS 67. Plaintiff restates and reallegesparagraphs 1-66 and incorporates them by
reference as Paragraph 67.

Rev. fackson, and Mq. Wiggins and the other Rainbow PUSH employees intentionally inflicted;insult, disparagement, badgering and caioling toward Mr. Bennett through the ridiculing comments and statements in the workplace and the exppsure to Rev.fackson'srequests. 69. Defendants' conduct was exEeme and ouffigeous, having a theme and/or undertone of sexualonientation. 74. Defendants'acts caused emotional distress to Mr. Bennett in the form of psychologicaland psydhiatric trauma.


Mr. Bennett continues to suffer severe emotional distress as a direct and proximate result of defendants'conduct WHEREFORE, Complainant Tommy Bennett prays this Honorable Court

enter judgment for him and againstDefendantsRev.Jesse lackson,Sr.,and Rainbow PUSHCoalitionfor the following amounts: D. $98,300 in back-pay, front-pay and loss of benefits, including but not limited to the COBRA premiums; E. $350,000for emotional distressand punitive damages; and F. Any further relief deemedfair, just, and equiAble.


His Attorney ThomasV. Leverso,Esq. Law Officesof ThomasV. Leverso Attorneys forthe Plaintiff- #46A47 33 West HigginsRoad,Suite 3080 SouthBarrington,Illinois 6001.0 Phone:630-936-9902 Fa* 530-527-L360

Sign up to vote on this title
UsefulNot useful