UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

Case Number:

MOYA STATEN,

 Plaintiff,

vs.

THE GEO GROUP, INC.,

 Defendant.

/

Complaint for Damages— Jury Trial Demanded

Plaintiff, Moya Staten, sues defendant The Geo Group, Inc., and as

grounds shows:

Introduction

1. This is a race, gender, and disability discrimination action brought

pursuant to The American with Disabilities Act, Title VII of the Civil Rights Act

of 1964 (“Title VII”), and the Florida Civil Rights Act, §§ 760.01, et seq., FLA.

STAT. (“FCRA”), by Moya Staten (“Staten”), human resources recruiting

coordinator against defendant, The Geo Group, Inc. (“The Geo Group”.) After

Staten, a female African American employee, applied for intermittent FMLA

leave for her migraines, and after she complained to human resources that it

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pa The Amlong Firm ! 500 Northeast Fourth Street ! Fort Lauderdale, FL 33301 ! 954.462.1983

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was not hiring minorities, The Geo Group consistently denied her promotions

and eventually terminated her.

Jurisdiction, Parties, Venue

2. This court has jurisdiction pursuant 28 U.S.C. §§ 1331 (federal

question). The court has supplemental jurisdiction to determine the state

claims pursuant to 28 U.S.C. § 1367.

3. Venue is proper in the Southern District of Florida pursuant to 28

U.S.C. § 1391(b) because the claims arose there and the defendant is

subject to personal jurisdiction there.

4. At all material times, plaintiff Moya Staten, was a female, African

American employee of The Geo Group, Inc., who suffered from migraines. 

As such, Staten was

a. an “employee” as envisioned by Title VII and the FCRA

b. a “qualified individual,” as envisioned by 42 U.S.C. §§

12111(8) and 12112(b)(4); and

c. protected by the anti-retaliation provisions of Title VII and

the FCRA.

5. At all times material, defendant The Geo Group, Inc. (“The Geo

Group”) was an “employer” as contemplated by 42 U.S.C. §12111(5) Title

VII ,and FCRA.

Applicable Statutes

6. The ADA at 42 U.S.C. § 12102 (“Definition of disability”) defines:

a. “disability,” in pertinent part, as:

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(1) [W]ith respect to an individual — 

(A) a physical or mental impairment that substantially

limits one or more major life activities of such individual; 

or . . .

(C) being regarded as having such an impairment (as

described in paragraph (3)).

b. “Major life activities,” in pertinent part, as including:

i. “thinking, communicating, and working,” and

ii. "the operation of a major bodily function, including

... neurological, brain [and] circulatory ... functions.

c. “Regarded as having such an impairment,” in pertinent

part, as being:

(3)(A). . . subjected to an action prohibited under this

chapter because of an actual or perceived physical or

mental impairment whether or not the impairment limits or

is perceived to limit a major life activity.

7. Title I of the ADA provides in pertinent part at 42 U.S.C. § 12112

(“Discrimination”):

(a) General rule. No covered entity shall discriminate against a

qualified individual on the basis of disability in regard to job

application procedures, the hiring, advancement, or discharge of

employees, employee compensation, job training, and other

terms, conditions, and privileges of employment.

(b) Construction. As used in subsection (a), the term

“discriminate against a qualified individual on the basis of

disability” includes — 

(1) limiting, segregating, or classifying a job applicant or

employee in a way that adversely affects the opportunities or

status of such applicant or employee because of the disability of

such applicant or employee;

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8. Title VII provides, in pertinent part, at 42 U.S.C. § 2000e-2(1)

that

It shall be an unlawful employment practice for an employer —

(1) to fail or refuse to hire or to discharge any individual, or

otherwise to discriminate against any individual with respect to his

compensation, terms, conditions, or privileges of employment,

because of such individual's race (or)... sex ...; or

(2) to limit, segregate, or classify his employees or applicants for

employment in any way which would deprive or tend to deprive any

individual of employment opportunities or otherwise adversely affect

his status as an employee, because of such individual's race (or) ...

sex ....

9. Title VII provides in pertinent part at 42 U.S.C. § 2000e-3(a)

that:

It shall be an unlawful employment practice for an employer to

discriminate against any of his employees . . . because he has opposed

any practice made an unlawful employment practice by this

subchapter, or because he has made a charge, testified, assisted, or

participated in any manner in an investigation, proceeding, or hearing

under this subchapter.

10. The FCRA provides at § 760.10(1), FLA. STAT., as follows:

It is an unlawful employment practice for an employer: 

(a) To discharge or to fail or refuse to hire any individual, or otherwise

to discriminate against any individual with respect to compensation,

terms, conditions, or privileges of employment, because of such

individual’s race, . . . sex [or] handicap . . . .

(b) To limit, segregate, or classify employees or applicants for

employment in any way which would deprive or tend to deprive any

individual of employment opportunities, or adversely affect any

individual’s status as an employee, because of such individual’s race, .

. . sex [or] handicap . . . .

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11. The FCRA provides in pertinent part at § 760.10(7), FLA. STAT.,

as follows: 

It is an unlawful employment practice for an employer . . . to

discriminate against any person because that person has opposed any

practice which is an unlawful employment practice under this section,

or because that person has made a charge, testified, assisted, or

participated in any manner in an investigation, proceeding or hearing

under this section.

Satisfaction of Conditions Precedent

12. Staten, on or about October 22, 2019, filed a Charge of

Discrimination with the Equal Employment Opportunity Commission

(“EEOC”) pursuant to the Title VII, and the ADA which also satisfied the filing

requirements and perfected her rights under the FCRA. 

13. The EEOC issued Staten a Notice of Right to Sue dated January

30, 2020, within 90 days of which Staten is filing suit.

14. The Florida Commission on Human Relations (“FCHR”) deferred

its handling of the case to the EEOC without either conciliating or making a

finding adverse to Staten within 180 days of the filing of the Charge of

Discrimination.

General Allegations

15. The Geo Group hired Moya Staten as a human resources

recruiting coordinator on or about September 6, 2016.

16. Plaintiff suffered from a disability, debilitating migraines, but she

could always performs the essential requirements of her job. 

17. In September 2017, Staten applied for intermittent FMLA leave

related to her migraines, which The Geo Group approved.

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18. After working in the same position for about two years, plaintiff

began applying for promotions, for which she was qualified, but was passed

over for other applicants:

a. On or about July 2018, Staten applied for the Sr. HR

Specialist Re-entry Position which was given to three other applicants — one

of whom was white;

b. On or about November 2018, Staten applied for the HR

Coordinator Position, which was given to a white applicant, after her

supervisor, Tom Arntz (“Arntz”), told the hiring manger that Staten was not

a “good fit” for the position;

c. On or about December 2018, Staten applied for a recruiter

re-entry position, which was given to a white applicant; 

d. On or about December 2018, Staten applied for a Recruiter

position but was not given the job after the hiring manager spoke with

Arntz, who had informed the hiring manger that Staten had migraines. 

19. Up until early 2019, The Geo Group was not hiring enough

minorities, and in February 2019 Staten complained to the HR department

about this.

20. Shortly thereafter, in February 2019, Staten applied for another

promotion, but it was given to another, less qualified male applicant, after

Arntz stated that the job may be too stressful for individuals who have

migraines. 

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21. On April 8, 2019, Staten passed out at work, due to her medical

condition, and had to miss work for one week.

22. When she returned, Arntz took away Staten’s background check

duties and knowingly put her on a job that would aggravate Staten’s

condition. 

23. Staten was confident that her migraines did not affect her ability

to perform her duties, and on or about, April 2019, Staten applied for the HR

Specialist position.

24. The interviewer told Staten that she was an excellent candidate

for the position, but that she could not offer her the position until her boss

spoke with Arntz. Staten did not get the position.

25. Plaintiff was fired on May 28, 2019.

Count I - Disability Discrimination Under Title I of the ADA: Actual

Disability

26. Staten realleges and adopts, as if they were fully set forth in this

Count all of the allegations of paragraphs 1-3; 4 b.; 5-7; 12-13; 15-18; and

20-25.

27. Staten’s application for FMLA leave for migraines indicated to

The Geo Group that Staten suffered from an impairment that substantially

limited one or more of a major life activity.

28. When Staten had her migraines, she could not go to work, drive,

or perform all normal daily activities. 

29. In addition to the allegations referenced herein, during the

December 2018 interview for a recruiter re-entry position, Arntz again

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informed Staten that the job is stressful and may not be a good fit for her,

given her headaches.

30. The Geo Group took adverse actions against Staten, when it

refused her promotions or job opportunities, and terminated her because

she suffered a disability.

31. The Geo Group’s actions were, therefore, in violation of the antidiscrimination provisions of the ADA.

32. As a direct, natural, and proximate result of The Geo Group’s

wrongful actions, State has suffered damages, including but not limited to,

lost wages, loss of earning capacity, and mental anguish.

33. The actions of defendant and its managing agents constituted a

wilful and wanton violation of Staten’s statutory rights against

discrimination, entitling her to recover punitive damages.

34. Staten additionally is suffering irreparable harm by being

deprived of her federal statutory right against discrimination, for which there

is not adequate remedy at law.

35. Staten is entitled to recover her reasonable attorney’s fees and

litigation expenses pursuant to 42 U.S.C. § 12133.

WHEREFORE, plaintiff, Moya Staten, respectfully requests this Court to

enter judgment for her and against defendant, The Geo Group:

One, determining and declaring that The Geo Group’s treatment of

Staten was in violation of Staten’s rights under Title I of the ADA;

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Two, enjoining defendant, its management and/or agents, from

discriminating against plaintiff, and affirmatively to make her whole,

including reinstatement, with restoration of seniority and benefits, or if that

is not practical, award her front pay;

Three, granting judgment against The Geo Group for damages,

including compensatory and punitive damages;

Four, awarding Staten her attorney’s fees and litigation expenses; and 

Five, granting such other and further relief as is just.

Count II - Disability Discrimination Under Title I of the ADA:

Perceived Disability

36. Staten realleges and adopts, as if they were fully set forth in this

Count all of the allegations of paragraphs 1-3; 4 b.; 5-7; 12-13; 15-18; 20-

25, and 28-29.

37. The Geo Group perceived that Staten suffered from an

impairment when Staten’s applied for FMLA due to her migraines.

38. The Geo Group took adverse actions against Staten, when it

refused her promotions or job opportunities, and terminated her because it

perceived her as suffering a disability.

39. The Geo Group’s actions were, therefore, in violation of the antidiscrimination provisions of the ADA.

40. As a direct, natural, and proximate result of The Geo Group’s

wrongful actions, State has suffered damages, including but not limited to,

lost wages, loss of earning capacity, and mental anguish.

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41. The actions of defendant and its managing agents constituted a

wilful and wanton violation of Staten’s statutory rights against

discrimination, entitling her to recover punitive damages.

42. Staten additionally is suffering irreparable harm by being

deprived of her federal statutory right against discrimination, for which there

is not adequate remedy at law.

43. Staten is entitled to recover her reasonable attorney’s fees and

litigation expenses pursuant to 42 U.S.C. § 12133.

WHEREFORE, plaintiff, Moya Staten, respectfully requests this Court to

enter judgment for her and against defendant, The Geo Group:

One, determining and declaring that The Geo Group’s treatment of

Staten was in violation of Staten’s rights under Title I of the ADA;

Two, enjoining defendant, its management and/or agents, from

discriminating against plaintiff, and affirmatively to make her whole,

including reinstatement, with restoration of seniority and benefits, or if that

is not practical, award her front pay;

Three, granting judgment against The Geo Group for damages,

including compensatory and punitive damages;

Four, awarding Staten her attorney’s fees and litigation expenses; and 

Five, granting such other and further relief as is just.

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Count III: Race Discrimination in Violation of Title VII

44. Staten realleges and adopts, as if fully set forth in this Count, all

of the allegations in paragraphs 1-4 a.; 5; 8; 12; 13; 15; 16; 18-20; and

22-25.

45. The Geo Group’s behavior towards Staten was based on her race

and, thus, constituted race discrimination as proscribed by 42 U.S.C. §

2000e-2(a).

46. As a direct, natural, proximate and foreseeable result of the

actions of The Geo Group, Staten has suffered past and future pecuniary

losses, emotional pain, suffering, inconvenience, mental anguish, loss of

enjoyment of life, and other non-pecuniary losses.

47. The discrimination that Staten is suffering, in violation of the

statutory rights to be free from such discrimination, constitutes irreparable

harm for which there is no adequate remedy at law. 

48. Staten is entitled to recover reasonable attorney’s fees and

litigation expenses pursuant to 42 U.S.C. § 2000e-5(k). 

WHEREFORE, Plaintiff, Moya Staten, prays that this Court will:

One, issue a declaratory judgment that defendant’s practices toward

plaintiff violated her rights against race discrimination under Title VII;

Two, enjoin defendant, its management employees and/or agents to

cease discriminating against plaintiff, to make her whole through back pay

and restoration of seniority and benefits; 

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Three, enter a judgment for plaintiff and against defendant for

damages, including compensatory damages;

Four, grant plaintiff her costs and reasonable attorney’s fees pursuant

to 42 U.S.C. § 2000e-5(k); and

Five, grant plaintiff such other and further relief as the circumstances

and law provide.

Count IV: Title VII Retaliation

49. Staten realleges and adopts, as if fully set forth in this Count, all

of the allegations in paragraphs 1-3; 4 a.; 4 c.; 5; 8-9; 12-13; 15-16; 18-

20; and 22-25.

50. Staten had a good faith belief that the failure to hire African

Americans in higher numbers was race discrimination in violation of Title VII

and the FCRA.

51. The adverse actions of defendant, including, but not limited to

denying her promotions, job opportunities, and eventually termination,

violated plaintiff’s rights against retaliation for complaining about or

opposing unlawful employment practices, including by her internal

complaints, which retaliation is proscribed by Title VII. 

69. As a direct, natural, proximate and foreseeable result of the

actions of The Geo Group, Staten has suffered past and future pecuniary

losses, emotional pain, suffering, inconvenience, mental anguish, loss of

enjoyment of life, and other non-pecuniary losses.

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52. The discrimination that Staten is suffering, in violation of the

statutory rights to be free from such discrimination, constitutes irreparable

harm for which there is no adequate remedy at law. 

53. Staten is entitled to recover reasonable attorney’s fees and

litigation expenses pursuant to 42 U.S.C. § 2000e-5(k). 

WHEREFORE, Plaintiff, Moya Staten, prays that this Court will:

One, issue a declaratory judgment that defendant’s practices toward

plaintiff violated her rights against retaliation under Title VII;

Two, enjoin defendant, its management employees and/or agents to

cease retaliating against plaintiff, to make her whole through back pay and

restoration of seniority and benefits; 

Three, enter a judgment for plaintiff and against defendant for

damages, including compensatory damages;

Four, grant plaintiff her costs and reasonable attorney’s fees pursuant

to 42 U.S.C. § 2000e-5(k); and

Five, grant plaintiff such other and further relief as the circumstances

and law provide.

Count V: Sex Discrimination in Violation of Title VII

54. Staten realleges and adopts, as if fully set forth in this Count, all

of the allegations in paragraphs 1-3; 4 a.; 5; 8; 12-13; 15-16; 18; 20; and

22-25.

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55. In addition, on or about March 14, 2019, Staten overheard Arntz

say to the individual who eventually got the position for which she had

applied, “[w]e need a man in the department. There are too many women.” 

56. The Geo Group’s behavior towards Staten was based on her sex

and, thus, constituted sex discrimination as proscribed by 42 U.S.C. §

2000e-2(a).

57. As a direct, natural, proximate and foreseeable result of the

actions of The Geo Group, Staten has suffered past and future pecuniary

losses, emotional pain, suffering, inconvenience, mental anguish, loss of

enjoyment of life, and other non-pecuniary losses.

58. The discrimination that Staten is suffering, in violation of the

statutory rights to be free from such discrimination, constitutes irreparable

harm for which there is no adequate remedy at law. 

59. Staten is entitled to recover reasonable attorney’s fees and

litigation expenses pursuant to 42 U.S.C. § 2000e-5(k). 

WHEREFORE, plaintiff, Moya Staten, prays that this Court will:

One, issue a declaratory judgment that defendant’s practices toward

plaintiff violated her rights against sex discrimination under Title VII;

Two, enjoin defendant, its management employees and/or agents to

cease discriminating against plaintiff, to make her whole through back pay

and restoration of seniority and benefits; 

Three, enter a judgment for plaintiff and against defendant for

damages, including compensatory damages;

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Four, grant plaintiff her costs and reasonable attorney’s fees pursuant

to 42 U.S.C. § 2000e-5(k); and

Five, grant plaintiff such other and further relief as the circumstances

and law provide.

Count VI: Handicap Discrimination under FCRA

60. Staten realleges and adopts, as if fully set forth in this Count, all

of the allegations in paragraphs 1-3; 4 a.; 5; 10; 12-18; 20-25; and 27-29.

61. Defendant’s behavior towards plaintiff was based on her

handicap or perceived handicap, and, thus, constituted a handicap

discrimination as proscribed by the FCRA.

62. As a direct, natural, and proximate result of The Geo Group’s

wrongful actions, State has suffered damages, including but not limited to,

lost wages, loss of earning capacity, and mental vanquish.

63. The actions of defendant and its managing agents constituted a

wilful and wanton violation of Staten’s statutory rights against

discrimination, entitling her to recover punitive damages.

64. Staten additionally is suffering irreparable harm by being

deprived of her federal statutory right against discrimination, for which there

is not adequate remedy at law.

65. Staten is entitled to recover her reasonable attorney’s fees and

litigation expenses pursuant to § 760.11(5) FLA. STAT.

WHEREFORE, plaintiff, Moya Staten, respectfully requests this Court to

enter judgment for her and against defendant, The Geo Group:

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One, determining and declaring that The Geo Group’s treatment of

Staten was in violation of Staten’s rights under the FCRA;

Two, enjoining defendant, its management and/or agents, from

discriminating against plaintiff, and affirmatively to make her whole,

including reinstatement, with restoration of seniority and benefits, or if that

is not practical, award her front pay;

Three, granting judgment against The Geo Group for damages,

including compensatory and punitive;

Four, awarding Staten her attorney’s fees and litigation expenses; and 

Five, granting such other and further relief as is just.

Count VII: Race Discrimination under FCRA

66. Staten realleges and adopts, as if fully set forth in this Count, all

of the allegations in paragraphs 1-3; 4 a.; 5; 10; 12-16; 18-20; and 22-25.

67. Defendant’s behavior towards plaintiff was based on her race,

and, thus, constituted a race discrimination as proscribed by the FCRA.

68. As a direct, natural, and proximate result of The Geo Group’s

wrongful actions, State has suffered damages, including but not limited to,

lost wages, loss of earning capacity, and mental anguish.

69. The actions of defendant and its managing agents constituted a

wilful and wanton violation of Staten’s statutory rights against

discrimination, entitling her to recover punitive damages.

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70. Staten additionally is suffering irreparable harm by being

deprived of her federal statutory right against discrimination, for which there

is not adequate remedy at law.

71. Staten is entitled to recover her reasonable attorney’s fees and

litigation expenses pursuant to § 760.11(5) FLA. STAT.

WHEREFORE, plaintiff, Moya Staten, respectfully requests this Court to

enter judgment for her and against defendant, The Geo Group:

One, determining and declaring that The Geo Group’s treatment of

Staten was in violation of Staten’s rights under the FCRA;

Two, enjoining defendant, its management and/or agents, from

discriminating against plaintiff, and affirmatively to make her whole,

including reinstatement, with restoration of seniority and benefits, or if that

is not practical, award her front pay;

Three, granting judgment against The Geo Group for damages,

including compensatory and punitive;

Four, awarding Staten her attorney’s fees and litigation expenses; and 

Five, granting such other and further relief as is just.

Count VIII: Retaliation FCRA

72. Staten realleges and adopts, as if fully set forth in this Count, all

of the allegations in paragraphs 1-3; 4 a.; 4 c.;5; 10-16; 18-20; and 22-25.

73. Staten had a good faith belief that the failure to hire African

Americans in higher numbers was race discrimination in violation of Title VII

and the FCRA.

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74. The adverse actions of defendant, including, but not limited to

denying her promotions, job opportunities, and eventually termination,

violated plaintiff’s rights against retaliation for complaining about or

opposing unlawful employment practices, including by her internal

complaints, which retaliation is proscribed by the FCRA. 

75. As a direct, natural, and proximate result of The Geo Group’s

wrongful actions, State has suffered damages, including but not limited to,

lost wages, loss of earning capacity, and mental anguish.

76. The actions of defendant and its managing agents constituted a

wilful and wanton violation of Staten’s statutory rights against

discrimination, entitling her to recover punitive damages.

77. Staten additionally is suffering irreparable harm by being

deprived of her federal statutory right against discrimination, for which there

is not adequate remedy at law.

78. Staten is entitled to recover her reasonable attorney’s fees and

litigation expenses pursuant to § 760.11(5) FLA. STAT.

WHEREFORE, plaintiff, Moya Staten, respectfully requests this Court to

enter judgment for her and against defendant, The Geo Group:

One, determining and declaring that The Geo Group’s treatment of

Staten was in violation of Staten’s rights under the FCRA;

Two, enjoining defendant, its management and/or agents, from

discriminating against plaintiff, and affirmatively to make her whole,

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including reinstatement, with restoration of seniority and benefits, or if that

is not practical, award her front pay;

Three, granting judgment against The Geo Group for damages,

including compensatory and punitive;

Four, awarding Staten her attorney’s fees and litigation expenses; and 

Five, granting such other and further relief as is just.

Count IX: Sex Discrimination under FCRA

79. Staten realleges and adopts, as if fully set forth in this Count, all

of the allegations in paragraphs 1-3; 4 a.; 5; 10-16; 18; 20; 22-25; and 55.

80. Defendant’s behavior towards plaintiff was based on her sex,

and, thus, constituted a sex discrimination as proscribed by the FCRA.

81. As a direct, natural, and proximate result of The Geo Group’s

wrongful actions, State has suffered damages, including but not limited to,

lost wages, loss of earning capacity, and mental anguish.

82. The actions of defendant and its managing agents constituted a

wilful and wanton violation of Staten’s statutory rights against

discrimination, entitling her to recover punitive damages.

83. Staten additionally is suffering irreparable harm by being

deprived of her federal statutory right against discrimination, for which there

is not adequate remedy at law.

84. Staten is entitled to recover her reasonable attorney’s fees and

litigation expenses pursuant to § 760.11(5) FLA. STAT.

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WHEREFORE, plaintiff, Moya Staten, respectfully requests this Court to

enter judgment for her and against defendant, The Geo Group:

One, determining and declaring that The Geo Group’s treatment of

Staten was in violation of Staten’s rights under the FCRA;

Two, enjoining defendant, its management and/or agents, from

discriminating against plaintiff, and affirmatively to make her whole,

including reinstatement, with restoration of seniority and benefits, or if that

is not practical, award her front pay;

Three, granting judgment against The Geo Group for damages,

including compensatory and punitive;

Four, awarding Staten her attorney’s fees and litigation expenses; and 

Five, granting such other and further relief as is just

Demand for Jury Trial

Staten demands trial by jury on all issues so triable.

Respectfully submitted,

/s/ Karen Coolman Amlong 

KAREN COOLMAN AMLONG

Florid Bar No. 275565

Kamlong@TheAmlongFirm.com 

WILLIAM R. AMLONG

Florida Bar No. 470228

WRAmlong@TheAmlongFirm.com

RANI NAIR BOLEN

Florida Bar No. 29293

Rbolen@TheAmlongFirm.com

The Amlong Firm 

500 Northeast Fourth Street

Fort Lauderdale, Florida 33301-1154

(954) 462-1983

 Attorneys for the Plaintiff

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