UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF FLORIDA

PENSACOLA DIVISION

BETTY YOUNG,

Plaintiff,

vs.

CENTURION OF FLORIDA, LLC and 

MHM HEALTH PROFESSIONALS,

LLC,

Defendants.

________________________/

Case No. __________________

COMPLAINT

Plaintiff Betty Young sues Defendants Centurion of Florida, LLC and 

MHM Health Professionals, LLC, and alleges:

Nature of the Action

1. This is an action to remedy unlawful race discrimination and 

retaliation under 42 U.S.C. § 2000e, et seq., 42 U.S.C. § 1981, and Florida 

Statutes § 760.01, et seq.

Parties

2. At all material times, Plaintiff Betty Young was a resident of 

Escambia County, Florida. Plaintiff is a member of a protected class because 

of her race (African-American) and because she reported and/or opposed 

unlawful employment practices.

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3. Defendant Centurion of Florida, LLC (“Centurion”) is a Florida

limited liability company organized and existing under the laws of the State 

of Florida. At all material times, Centurion has been an “employer” as that 

term is used under the applicable laws.

4. Defendant MHM Health Professionals, LLC (“MHMHP”), is a 

foreign limited liability company authorized and doing business in the State 

of Florida. At all material times, MHMHP has been an “employer” as that 

term is used under the applicable laws.

Jurisdiction and Venue

5. This Court has jurisdiction under 28 U.S.C. § 1331 because 

Plaintiff asserts claims arising under the laws of the United States. 

6. The Court has supplemental jurisdiction over Plaintiff’s state-law 

claims under 28 U.S.C. § 1367(a) because those claims are so related to the 

federal claims that they form part of the same case or controversy.

7. Venue is proper in this Court because a substantial part of the 

events or omissions giving rise to the claims occurred in this District.

Conditions Precedent

8. Plaintiff has satisfied all conditions precedent to bringing this 

action.

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Factual Allegations

9. Centurion and MHMHP jointly employed Plaintiff.

10. Plaintiff began her employment with Defendants in November 

2018 as an Activities Technician at the Santa Rosa Correctional Institution 

(“SRCI”) in Milton, Florida.

11. On April 9, 2019, Plaintiff walked into the medical offices at SRCI 

and saw several Corrections Officers huddled over an African-American 

inmate who appeared to have been beaten. Plaintiff recognized the inmate 

as one who also had been beaten by Corrections Officers in January 2019. 

12. As Plaintiff was leaving the medical offices, she heard someone 

refer to her as “black bitch.”

13. Plaintiff immediately reported the incident to her supervisor, 

who instructed Plaintiff to prepare an incident report and submit it to her 

supervisor for her review. Plaintiff did as her supervisor instructed. She later 

learned that her supervisor had deleted from the report that Plaintiff had 

heard someone refer to her as “black bitch.”

14. On April 10, 2019, Plaintiff was suspended pending an 

investigation.

15. On April 23, 2019, Plaintiff’s employment was terminated. 

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COUNT 1

RACE DISCRIMINATION

16. Plaintiff realleges paragraphs 1 through 15 above.

17. Plaintiff has been discriminated against because of her race in 

that she was treated differently than similarly situated non-AfricanAmerican employees based, at least in part, on her race. 

18. Defendants are liable for the differential treatment towards 

Plaintiff because they controlled the actions and inactions of the persons 

making decisions affecting Plaintiff or they knew or should have known 

about those actions or inactions and failed to take prompt and adequate 

remedial action or took no action at all to prevent the abuses of Plaintiff.

19. Defendants also knowingly condoned and ratified the differential 

treatment of Plaintiff because they allowed and/or participated in the 

differential treatment.

20. The discrimination complained of herein affected a term,

condition, or privilege of Plaintiff’s employment with Defendants and 

constitutes adverse employment action.

21. Defendants’ acts and omissions constitute intentional 

discrimination and unlawful employment practices based on race, in 

violation of 42 U.S.C. § 1981, 42 U.S.C. § 2000e, et seq., and Florida Statutes 

§ 760.01, et seq.

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22. As a direct and proximate result of Defendants’ 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 and other non-pecuniary losses. These damages 

have occurred in the past, are permanent and continuing. Plaintiff is entitled 

to injunctive relief.

23. Plaintiff is entitled to recover her attorney’s fees and costs under 

42 U.S.C. § 1988, 42 U.S.C. § 2000e-5(k), and Florida Statutes § 760.11(5).

COUNT 2

RETALIATION

24. Plaintiff realleges paragraphs 1 through 15 above.

25. Plaintiff reported and/or opposed unlawful employment 

practices during her employment with Defendants.

26. Defendants retaliated against Plaintiff for reporting and/or 

opposing the unlawful employment practices.

27. As a direct and proximate result of Defendants’ acts and 

omissions, Plaintiff has suffered emotional distress, mental pain and 

suffering, past and future pecuniary losses, inconvenience, mental anguish, 

loss of enjoyment of life and other non-pecuniary losses. These damages 

have occurred in the past, are permanent and continuing. Plaintiff is entitled 

to injunctive relief.

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28. Plaintiff is entitled to recover her attorney’s fees and costs under 

42 U.S.C. § 1988, 42 U.S.C. § 2000e-5(k), and Florida Statutes § 760.11(5).

PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays that the Court enter judgment in her

favor and against Defendants awarding compensatory damages, punitive 

damages, pre- and post-judgment interest, attorney’s fees, and costs;

granting equitable relief mandating Defendants’ obedience to the laws 

enumerated above and permanently enjoining Defendants from future 

violations of those laws; and granting such other and further relief as the

Court deems just and appropriate.

DEMAND FOR JURY TRIAL

Plaintiff demands a trial by jury on all matters so triable.

DATED: September 14, 2020

TEIN MALONE PLLC

/s/ Gaye L. Huxoll

Gaye L. Huxoll

Florida Bar No. 149497

ghuxoll@teinmalone.com

(305) 442-1101

Counsel for Plaintiff

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