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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF FLORIDA

PANAMA CITY DIVISION

QUINTAY E. GOODEN,

Plaintiff, 

v. CASE NO.

MEGAN J. BRENNAN, in her official 

Capacity as POSTMASTER GENERAL,

UNITED STATED POSTAL SERVICE,

Defendant.

_______________________________________/

COMPLAINT

Plaintiff, QUINTAY E. GOODEN, hereby sues Defendant, MEGAN J. 

BRENNAN, in her official capacity as POSTMASTER GENERAL, UNITED 

STATES POSTAL SERVICE, and alleges:

NATURE OF THE ACTION

1. This is an action brought under 42 U.S.C. §2000e et seq. (Title VII); 42 

U.S.C §1981a; and 29 U.S.C. §794 (The Rehabilitation Act). Jurisdiction of this 

Court is invoked pursuant to 28 U.S.C. §1331 (federal question jurisdiction) and 28 

U.S.C. §1343 (civil rights claim jurisdiction). Costs and attorney’s fees are also 

sought under 5 U.S.C. §504 and/or 28 U.S.C. §2412.

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2. Demand is made herein for damages in excess of Seventy-Five 

Thousand Dollars ($75,000.00). Declaratory, injunctive, legal, and equitable relief 

is sought pursuant to the laws set forth above together with attorney’s fees, costs, 

and damages.

CONDITIONS PRECEDENT

3. Plaintiff has satisfied all conditions precedent to bringing this action 

in that Plaintiff filed a charge of discrimination with the Equal Employment 

Opportunity office within the Defendant. This action is timely brought thereafter.

THE PARTIES

4. At all times pertinent hereto, Plaintiff, QUINTAY E. GOODEN, has 

been a resident of the State of Georgia and was employed by Defendant in Florida.

Plaintiff performs all job duties in Florida. She is, thus, sui juris. Plaintiff is a 

member of a protected class because of her gender (female), pregnancy, disability, 

and retaliation (EEO activity). 

5. At all times pertinent hereto, Defendant, MEGAN J. BRENNAN, in her 

official capacity as POSTMASTER GENERAL of the UNITED STATES POSTAL 

SERVICE (“USPS”), has been operating and existing under the laws of the United 

States of America, doing business under the laws of the United States of American 

and the State of Florida. At all times alleged, Defendant was Plaintiff’s “employer” 

as the term is used under the applicable laws identified above. 

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STATEMENT OF THE ULTIMATE FACTS

6. Plaintiff began her employment with Defendant on August 21, 2017, in 

New York, and transferred to Florida on February 20, 2018.

7. Plaintiff was subjected to disparate treatment, different terms and 

conditions of employment, held to a different standard because of her race, gender, 

pregnancy, and disability, and was retaliated against after reporting unlawful 

employment practices and disparate treatment.

8. The continuous disparate treatment came at the hands of specifically, 

but not limited to, Managers Megan Barber (white female), Paul Jones (black male), 

Jaquesia Hail (black female), and Supervisor Jeanie Green (white female).

9. Plaintiff encountered disparate treatment at the USPS Gulf Main 

Facility (GMF) as well as USPS Leon County Facility. 

10. At the USPS GMF location, beginning in or around mid 2018, Manager 

Jones changed Plaintiff’s hours, giving priority to other employees with less 

seniority. Specifically, Jamarcus Cole, a black male, was given preferential 

treatment in terms of the number of hours, shift assignments, and days off. This is 

one of many instances Plaintiff was treated unfairly due to her gender by Jones. 

11. Because of the disparate treatment of Plaintiff as compared to her male 

counterparts, on January 16, 2019, Plaintiff filed an EEO complaint regarding 

Manager Jones discriminatory practices. Manager Jones behavior did not improve 

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after the complaint was filed but got worse and the retaliation started.

12. In April 2019, while at work at the Gulf location, Plaintiff injured her 

knee on the job due to a malfunctioning lift on a truck. Plaintiff informed Manager 

Barber of the injury and Manager Barber instructed Plaintiff to come to her office to 

get the paperwork needed to report an on the job injury. Plaintiff went to retrieve the 

paperwork. Upon arriving, Manager Barber commented to Plaintiff stating there was 

nothing wrong with her knee. Plaintiff waited for the paperwork in the office of 

Manager Barber for approximately 3-4 hours. During this time, Plaintiff was sitting 

quietly waiting on the paperwork and even talked to her union representative at this 

time as well. After about 3-4 hours, Plaintiff respectfully questioned Manager Barber 

regarding how much longer the paperwork would take. Manager Barber then told 

Plaintiff to get out of her office or she was going to call the police. Afraid and 

confused, Plaintiff went to a different location when told to leave. Boyd informed 

an additional union representative, Robert Mongeon, the police were called and 

Mongeon went to aid Plaintiff.

13. Manager Barber, unbelievably, called the police on Plaintiff and when 

they arrived in the scene, they informed Plaintiff she was reported to them for

cussing. This was a false claim against Plaintiff. 

14. Plaintiff became extremely anxious, began shaking, and 

hyperventilating because of this false allegation against her. Plaintiff has asthma 

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which was known or should have been known by the Defendant due to Plaintiff’s 

use of an inhaler while on the job. Paramedics even had to be called because Plaintiff 

was having a panic/anxiety attach while still trying to deal with her asthma. She was 

told by the paramedics not to drive until she calmed down. However, Barber then 

threatened to call the police again if Plaintiff and Mongeon did not leave the location. 

Mongeon drove the Plaintiff’s car out of the location in light of this threat. 

15. During Plaintiff’s time of employment, Plaintiff never witnessed police 

being called on any other employee. 

16. In early June 2019, Plaintiff submitted a document requesting a 

modified job offer due to her knee injury. Manager Jones indicated there was no 

work available. Plaintiff was then marked by Manager Jones as AWOL. On June 13, 

2019, a Pre-Disciplinary Interview (PDI) was held in which Dan Becker, the 

Postmaster General, Manager Jones, Plaintiff, Boyd, and Mongeon were present. 

When the Union Representatives left the room to make copies, Manager Jones

physically threatened Plaintiff saying “I’m going to jack you up.” Later that day, 

Plaintiff informed Dan Becker of what Manager Jones said. Manager Jones was not 

disciplined but Plaintiff was thereafter transferred to USPS Leon. This is one of 

many instances the Plaintiff was treated unfairly due to her gender.

17. In June 2019, Plaintiff was transferred to a different USPS location, 

Leon County Post Office. Supervisor Jeanie Green became Plaintiff’s supervisor and 

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Manager Hail became Plaintiff’s manager. 

18. On October 9, 2019, the Plaintiff was placed on bed rest by her doctor

due to serious medical complications due to her pregnancy rising to the level of a 

disability. On November 9, 2019, the Plaintiff was cleared by her doctor to return 

to work under certain restrictions. The Plaintiff could only lift up to ten pounds and 

needed to take a ten minute break every two hours. Plaintiff was ready, able, and 

willing to return to work. 

19. Supervisor Green refused to allow Plaintiff back at work due to her 

pregnancy. This is one of instances the Plaintiff was retaliated and discriminated 

against based on her pregnancy/disability. 

20. On October 10, 2019, Plaintiff filed an addition EEO complaint 

regarding discriminatory practices by management and supervisors. These managers 

and supervisors have yet to correct their discriminatory behavior. 

21. From November 9, 2019 until December 21, 2019, Plaintiff was not 

permitted to work. On or around December 21, 2019, Supervisor Green offered 

Plaintiff a position as a caser up for two hours a day. This is a substantial reduction 

in the number of hours that Plaintiff was working prior to her pregnancy. 

22. In early January 2020, Manager Hail questioned Plaintiff regarding the 

status of her dilation and if the Plaintiff was having sex. Plaintiff was offended and 

shocked by these questions. Plus, Hail and Plaintiff did not have a close personal 

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relationship that would permit such conversation.

23. Although Plaintiff gave Defendant multiple opportunities to address the

issues identified above without success. 

24. Plaintiff has retained the undersigned to represent her interests in this 

cause and is obligated to pay a fee for these services. Defendant should be made to 

pay said fee under the laws referenced above.

COUNT I

GENDER BASED DISCRIMINATION

25. Paragraphs 1 through 24 are re-alleged and incorporated herein by 

reference.

26. This is an action against Defendant for discrimination based upon 

gender brought under 42 U.S.C. §2000e et seq.. for the time period that Plaintiff 

was located at the GMF facility.

27. Plaintiff has been the victim of discrimination on the basis of 

Plaintiff’s gender in that Plaintiff was treated differently than similarly situated 

employees of Defendant who are male and has been subject to poor treatment on 

the basis, at least in part, of Plaintiff’s gender.

28. Defendant is liable for the differential treatment Plaintiff because it 

controlled the actions and inactions of the persons making decisions affecting 

Plaintiff or it knew or should have known of these actions and inactions and failed 

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to take prompt and adequate remedial action or took no action at all to prevent the

abuses to Plaintiff. 

29. Furthermore, Defendant knowingly condoned and ratified the 

differential treatment of Plaintiff as more fully set forth above because it allowed 

the differential treatment and participated in same. 

30. Defendant's known allowance and ratification of these actions and 

inactions actions created, perpetuated and facilitated an abusive and offensive work 

environment within the meaning of the statutes referenced above.

31. In essence, the actions of agents of Defendant, which were each 

condoned and ratified by Defendant, were of a gender-based nature and in 

violation of the laws set forth herein. 

32. The discrimination complained of herein affected a term, condition, or 

privilege of Plaintiff's continued employment with Defendant. The events set forth 

herein led, at least in part, to adverse action against Plaintiff. 

33. Defendant's conduct and omissions constitutes intentional 

discrimination and unlawful employment practices based upon gender in violation 

of 42 U.S.C. §2000e et seq.

34. As a direct and proximate result of Defendant's conduct described 

above, Plaintiff has suffered emotional distress, mental pain and suffering, past and 

future pecuniary losses, inconvenience, mental anguish, loss of enjoyment of life 

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and other non-pecuniary losses, along with lost back and front pay, interest on pay, 

bonuses, and other benefits. These damages have occurred in the past, are 

permanent and continuing. Plaintiff is entitled to injunctive and equitable relief.

COUNT II

PREGNANCY DISCRIMINATION

44. Paragraphs 1 through 24 are realleged and incorporated herein by 

reference.

45. This is an action against Defendant for discrimination based upon 

pregnancy.

46. Plaintiff has been the victim of discrimination on the basis of her

pregnancy in that Plaintiff was treated differently than similarly situated employees 

of Defendant who are not pregnant and has been subject to hostility and poor 

treatment on the basis, at least in part, of her pregnancy.

47. Defendant is liable for the differential treatment and hostility towards 

Plaintiff because it controlled the actions and inactions of the persons making 

decisions affecting Plaintiff or it knew or should have known of these actions and 

inactions and failed to take prompt and adequate remedial action or took no action 

at all to prevent the abuses to Plaintiff. Furthermore, Defendant knowingly 

condoned and ratified the differential treatment of Plaintiff as more fully set forth 

above because it allowed the differential treatment and participated in same. 

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48. Defendant’s known allowance and ratification of these actions and 

inactions actions created, perpetuated and facilitated an abusive and offensive work 

environment within the meaning of the statutes referenced above.

49. In essence, the actions of agents of Defendant, which were each 

condoned and ratified by Defendant, were of a pregnancy-based nature and in 

violation of the laws set forth herein. 

50. The discrimination complained of herein affected a term, condition, or 

privilege of Plaintiff's continued employment with Defendant. The events set forth 

herein lead, at least in part, to adverse action against Plaintiff. 

51. Defendant’s conduct and omissions constitutes intentional 

discrimination and unlawful employment practices based upon pregnancy.

52. As a direct and proximate result of Defendant’s conduct described 

above, Plaintiff has suffered emotional distress, mental pain and suffering, past and 

future pecuniary losses, inconvenience, bodily injury, mental anguish, loss of 

enjoyment of life and other non-pecuniary losses, along with lost back and front 

pay, interest on pay, bonuses, and other benefits. These damages have occurred in 

the past, are permanent and continuing. Plaintiff is entitled to injunctive and 

equitable relief.

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COUNT III

DISABILITY DISCRIMINATION

53. Paragraphs 1 through 24 are incorporated herein by reference.

54. This count sets forth a claim against Defendant for discrimination based 

on handicap/disability, Defendant’s perception of Plaintiff as disabled and/or 

Plaintiff’s record of having an impairment.

55. Defendant, through its agents, apparent agents, and employees, because 

of Plaintiff’s handicapped/disability targeted Plaintiff and refused to accommodate 

her and/or to engage in the interactive process with her. Defendant took against 

Plaintiff because of her disabling condition, i.e., pregnancy, by way of example but 

not limitation, she had limitations in her ability to life heavy objects, walk, stand, 

squat, and bend, and/or Defendant’s perception of Plaintiff as being disabled. 

Alternatively, Defendant perceived Plaintiff to be disabled and took action against 

her as a result thereof and/or failed to reasonably accommodate her.

56. There is no legitimate reason that has been presented, nor can there be 

any legitimate reason, for the adverse treatment of Plaintiff.

57. Defendant harbored ill-motives and intent to cause disparate and 

discriminatory treatment of Plaintiff.

58. Defendant knew or should have known of these conditions as they were 

open and notorious and well known to Defendant. The adverse treatment of Plaintiff, 

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together with the facts set forth above, were brought to the attention of Defendant 

and Defendant perpetuated this treatment by condoning the actions and inactions 

affecting Plaintiff. 

59. Defendant is responsible for the violations of Plaintiff's rights as set 

forth herein because it exercised control over the adverse treatment of Plaintiff. In 

the alternative, Defendant failed to properly supervise its employees thereby causing 

foreseeable harm to Plaintiff's rights set forth herein.

60. As a direct and proximate result of Defendant's actions described 

above, Plaintiff has sustained damages including but not limited to mental, nervous, 

and emotional injury. Plaintiff has incurred additional damages including lost 

wages, pain and suffering, mental anguish, loss of capacity for the enjoyment of life, 

and other damages. These damages have occurred in the past, are occurring at 

present and will continue in the future. Plaintiff is entitled to injunctive/equitable 

relief.

COUNT IV

RETALIATION

69. Paragraphs 1 through 24 are realleged and incorporated herein by 

reference.

70. Defendant is an employer as that term is used under the applicable 

statutes referenced above.

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71. The foregoing allegations establish a cause of action for unlawful 

retaliation after Plaintiff reported or opposed unlawful employment practices 

adversely affecting Plaintiff under 42 U.S.C § 2000e et seq. and other laws cited 

above.

72. The foregoing unlawful actions by Defendant were purposeful.

73. Plaintiff voiced opposition to unlawful employment practices during 

Plaintiff’s employment with Defendant and was the victim of retaliation thereafter, 

as related in part above.

74. Plaintiff is a member of a protected class because of her race, and 

because Plaintiff reported unlawful employment practices and was the victim of 

retaliation thereafter. There is thus a causal connection between the reporting of the 

unlawful employment practices and the adverse employment action taken thereafter.

75. As a direct and proximate result of the foregoing unlawful acts and 

omissions, Plaintiff has suffered mental anguish, emotional distress, expense, loss 

of benefits, embarrassment, humiliation, damage to reputation, illness, lost wages, 

loss of capacity for the enjoyment of life, and other tangible and intangible damages. 

These damages are continuing and are permanent. Plaintiff is entitled to injunctive 

relief.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays for the following relief: 

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(a) that process issue and this Court take jurisdiction over this case; 

(b) that this Court grant equitable relief against Defendant under the 

applicable counts set forth above, mandating Defendant’s obedience 

to the laws enumerated herein and providing other equitable relief to 

Plaintiff including reinstatement; 

(c) enter judgment against Defendant and for Plaintiff awarding damages 

to Plaintiff from Defendants for Defendant’s violations of law 

enumerated herein; 

(d) enter judgment against Defendant and for Plaintiff permanently 

enjoining Defendant from future violations of law enumerated herein; 

(e) enter judgment against Defendant and for Plaintiff awarding costs; 

(f) award Plaintiff interest; and 

(g) grant such other further relief as being just and proper under the 

circumstances.

DEMAND FOR TRIAL BY JURY

Plaintiff hereby demands a trial by jury on all issues set forth herein which 

are so triable.

Dated this 17th day of January 2020.

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Respectfully submitted,

s/ Marie A. Mattox

Marie A. Mattox [FBN 0739685]

MARIE A. MATTOX, P.A.

203 North Gadsden Street

Tallahassee, FL 32301

Telephone: (850) 383-4800

Facsimile: (850) 383-4801

ATTORNEYS FOR PLAINTIFF

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