IN THE UNITED STATES DISTRICT COURT FOR THE 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

CARLA RANSOM, ) 

) 

Plaintiff, ) No. 

) 

vs. ) Judge 

) 

LEVY SECURITY CORPORATION, ) Magistrate Judge 

an Illinois Corporation, ) 

 ) 

Defendants. ) 

COMPLAINT AT LAW

NOW COMES the plaintiff, CARLA RANSOM, by and through her attorneys 

Seth R. Halpern and Carlie S. Marvel of MALKINSON & HALPERN, P.C., and 

complains of the defendant, LEVY SECURITY CORPORATION, an Illinois 

corporation, as follows: 

GENERAL ALLEGATIONS

 1. Plaintiff, CARLA RANSOM (hereinafter "RANSOM" or “plaintiff”), is 

an African-American citizen of the State of Indiana and presently resides at 879 Joliet 

Street, Unit 110, in the City of Dyer, County of Lake, State of Indiana. 

 2. Defendant, LEVY SECURITY CORPORATION (hereinafter referred to 

as “LEVY” or “defendant”) is an Illinois corporation doing business in Illinois. At all 

relative times, defendant had a business office and conducted business at 8750 West Bryn 

Mawr Avenue, in the City of Chicago, County of Cook, State of Illinois. Defendant is 

engaged in an industry affecting commerce and, at all times pertinent hereto, was an 

employer within the meaning of 42 U.S.C. 2000e(b). 

 3. This court has jurisdiction of this case pursuant to Title VII of the Civil 

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Rights Act of 1964 (hereinafter “TITLE VII”), 42 U.S.C. 2000e, et seq., the Americans 

with Disabilities Act of 1990 (hereinafter the “ADA”), 42 U.S.C. 12101 et seq. and 

Section 7 of the Age Discrimination in Employment Act (hereinafter “ADEA”), 29 

U.S.C. 621 et seq. 

4. This action properly lies in this district pursuant to 28 U.S.C. 1391 

because the claim arose in this judicial district. 

 5. Plaintiff has complied with all administrative prerequisites by filing timely 

Charges of Discrimination with the Equal Employment Opportunity Commission 

(hereinafter "EEOC") on July 21, 2009 and June 2, 2010. A copy of the Charges of 

Discrimination are attached hereto as Group Exhibit A. 

6. On or about August 12, 2011, the EEOC issued to plaintiff Notices of 

Right to Sue pertaining to the above referenced Charges of Discrimination, attached 

hereto as Group Exhibit B. 

7. In approximately December of 2005, LEVY hired RANSOM as a Security 

Officer. At all relevant times, RANSOM worked for LEVY at the Illinois Institute of 

Technology (hereinafter “IIT”), located at 3300 S. Michigan Avenue, in the City of 

Chicago, County of Cook, State of Illinois. 

8. At all relevant times, RANSOM performed her job in a satisfactory 

manner. 

9. In approximately May of 2007 and April of 2008, RANSOM sustained 

work-related injuries to her left knee. On approximately July 21, 2008, RANSOM filed 

claims against LEVY at the Illinois Workers’ Compensation Commission so that she 

could begin receiving workers’ compensation benefits for her work-related injuries. 

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10. RANSOM was out on medical leave due to the above-referenced injuries 

from approximately July 11, 2008 to approximately January 6, 2009. 

11. Upon her return from medical leave on approximately January 6, 2009, 

and continuing until approximately December 22, 2009, RANSOM, in good faith, 

believed that LEVY was engaging in a course of unlawful discrimination against her 

based on her age at the time, forty (40), sex, female, race, black and disability. RANSOM 

also believed, in good faith, that LEVY was retaliating against her for making complaints 

of the aforementioned discrimination. 

12. On approximately April 3, 2009, RANSOM sustained work-related 

injuries to her neck, back and shoulder. On approximately April 23, 2009, RANSOM 

filed a claim against LEVY at the Illinois Workers’ Compensation Commission so that 

she could begin receiving workers’ compensation benefits for her work-related injuries. 

13. On approximately June 2, 2009, RANSOM sustained a work-related 

injury to her left knee. 

14. On July 21, 2009, RANSOM filed a Charge of Discrimination against 

LEVY with the EEOC regarding the aforementioned age, sex, race and disability 

discrimination and retaliation. 

15. On approximately July 31, 2009, RANSOM filed a claim against LEVY at 

the Illinois Workers’ Compensation Commission so that she could begin receiving 

workers’ compensation benefits for the work-related injuries she sustained on June 2, 

2009.

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16. On approximately August 17, 2009, RANSOM complained to LEVY 

about being sexually harassed by an independent contractor who worked with her at the 

IIT. 

17. On approximately September 2, 2009, LEVY directed that RANSOM 

undergo a Fitness for Duty Evaluation and placed RANSOM on an involuntary leave of 

absence in retaliation for exercising her rights under the Illinois Workers’ Compensation 

Act, 820 ILCS 305/1 et. seq, for filing a Charge of Discrimination with the EEOC and for 

her complaints of retaliation, sexual harassment, and age, race, sex and disability 

discrimination. 

18. On approximately December 22, 2009, LEVY terminated RANSOM in 

retaliation for exercising her rights under the Illinois Workers’ Compensation act, for 

filing a Charge of Discrimination with the EEOC and for her complaints of retaliation, 

sexual harassment, and age, race, sex and disability discrimination. 

COUNT I – IMPERMISSIBLE RETALIATION – TITLE VII

1-18. Plaintiff repeats and re-alleges Paragraphs 1-18 of the Common 

Allegations as though fully set forth herein. 

19. The foregoing constitutes impermissible retaliation in violation of Title 

VII of the Civil Rights Act of 1964 as amended, 42 U.S.C. Sec. 2000e-2(a). 

20. LEVY’s course of conduct toward RANSOM showed a willful and/or 

reckless disregard of RANSOM’S rights to employment free from impermissible 

retaliatory conduct. 

21. As a result of the unlawful employment practices complained of herein, 

plaintiff experienced, and continues to experience, loss of wages and benefits, and 

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suffered and continues to suffer from severe emotional distress, embarrassment, 

humiliation and mental anguish. 

WHEREFORE, plaintiff, CARLA RANSOM respectfully prays that this Court 

enter an order: 

(a) Declaring that the conduct of LEVY SECURITY CORPORATION, as 

described herein, is in violation of Title VII of the Civil Rights Act of 

1964, as amended, 42 U.S.C. Sec. 2000e, et seq.; 

(b) Awarding CARLA RANSOM the salary, with interest, she has lost as a 

result of LEVY SECURITY CORPORATION’s conduct; 

(c) Awarding CARLA RANSOM compensatory and punitive damages; 

(d) Awarding CARLA RANSOM reasonable attorneys' fees and costs under 

42 U.S.C. Sec. 2000(e) - 5(k); and 

 

(e) Awarding CARLA RANSOM such other and further relief as this Court 

deems proper and just. 

COUNT II – IMPERMISSIBLE RETALIATION – ADA

1-18. Plaintiff repeats and re-alleges Paragraphs 1-18 of the Common 

Allegations as though fully set forth herein. 

19. The foregoing constitutes impermissible retaliation in violation of the 

Americans with Disabilities Act of 1990, 42 U.S.C. Sec. 12103(a). 

20. LEVY’s course of conduct toward RANSOM showed a willful and/or 

reckless disregard of RANSOM’S rights to employment free from impermissible 

retaliatory conduct. 

21. As a result of the unlawful employment practices complained of herein, 

plaintiff experienced, and continues to experience, loss of wages and benefits, and 

suffered and continues to suffer from severe emotional distress, embarrassment, 

humiliation and mental anguish. 

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WHEREFORE, plaintiff, CARLA RANSOM respectfully prays that this Court 

enter an order: 

 (a) Declaring that the conduct of LEVY SECURITY CORPORATION as 

described herein is in violation of the Americans with Disabilities Act of 

1990, 42 U.S.C. Sec. 12101 et seq.; 

(b) Awarding CARLA RANSOM the salary, with interest, she has lost as a 

result of LEVY SECURITY CORPORATION’s conduct; 

(c) Awarding CARLA RANSOM compensatory and punitive damages; 

(d) Awarding CARLA RANSOM reasonable attorneys' fees and costs under 

42 U.S.C. Sec. 12101 et seq.; and 

(e) Awarding CARLA RANSOM such other and further relief as this Court 

deems proper and just. 

COUNT III – IMPERMISSIBLE RETALIATION – ADEA

1-18. Plaintiff repeats and re-alleges Paragraphs 1-18 of the Common 

Allegations as though fully set forth herein. 

 19. The foregoing constitutes impermissible retaliation in violation of the Age 

Discrimination in Employment Act, 29 U.S.C. Sec. 621 et seq. 

20. LEVY’s course of conduct toward RANSOM showed a willful and/or 

reckless disregard of RANSOM’S rights to employment free from impermissible 

retaliatory conduct. 

21. As a result of the unlawful employment practices complained of herein, 

plaintiff experienced, and continues to experience, loss of wages and benefits, and 

suffered and continues to suffer from severe emotional distress, embarrassment, 

humiliation and mental anguish. 

WHEREFORE, plaintiff, CARLA RANSOM respectfully prays that this Court 

enter an order: 

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(a) Declaring that the conduct of LEVY SECURITY CORPORATION as 

described herein is in violation of The Age Discrimination in Employment 

Act, 29 U.S.C. Sec. 623(d); 

(b) Awarding CARLA RANSOM the salary, with interest, she has lost as a 

result of LEVY SECURITY CORPORATION’s conduct; 

(c) Awarding CARLA RANSOM compensatory and punitive damages; 

(d) Awarding CARLA RANSOM reasonable attorneys' fees and costs under 

29 U.S.C. Sec. 621 et seq.; and 

(e) Awarding CARLA RANSOM such other and further relief as this Court 

deems proper and just. 

COUNT IV – ILLINOIS WORKERS’ COMPENSATION ACT

1-18. Plaintiff repeats and re-alleges Paragraphs 1-18 of the Common 

Allegations as though fully set forth herein. 

19. The State of Illinois clearly prohibits any employer from engaging in any 

retaliatory or discriminatory conduct against any employee because the employee 

exercises his/her rights under the Workers' Compensation Act, 820 ILCS 305/1 et seq,

(hereinafter "the Act"). Section 4(h) of the Act provides in relevant part that: 

It shall be unlawful for any employer, insurance company or service or 

adjustment company to interfere with, restrain or coerce an employee in 

any manner whatsoever in the exercise of the rights or remedies granted to 

him or her by this Act or to discriminate, attempt to discriminate, or 

threaten to discriminate against an employee in any way because of his or 

her exercise of the rights or remedies granted to him or her by this Act. 

It shall be unlawful for any employer, individually or through any 

insurance company or service or adjustment company, to discharge or to 

threaten to discharge, or to refuse to rehire or recall to active service in a 

suitable capacity an employee because of the exercise of his or her rights 

or remedies granted to him or her by this Act. 

20. LEVY violated clearly mandated public policy of the State of Illinois 

when it terminated plaintiff because she exercised her rights under the Workers' 

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Compensation Act, 820 ILCS 305/1 et. seq. 

21. As a direct and proximate result of the above-mentioned incidents and 

conduct of LEVY, plaintiff experienced, and continues to experience, lost wages and 

benefits, and suffered and continues to suffer from emotional distress. 

WHEREFORE, plaintiff, CARLA RANSOM, prays for judgment against LEVY 

SECURITY CORPORATION in an amount in excess of Seventy-Five Thousand 

($75,000) Dollars plus costs and for all other relief this court deems appropriate. 

PLAINTIFF DEMANDS TRIAL BY JURY OF ALL ISSUES HEREIN. 

DATE: November 9, 2011 

Respectfully submitted, 

By: /s/ Seth R. Halpern_____ 

Counsel for Plaintiff 

Seth R. Halpern 

Carlie S. Marvel 

MALKINSON & HALPERN, P.C. 

208 S. LaSalle Street, Suite 1750 

Chicago, IL 60604 

(312) 427-9600 

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