UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

GLENDA SINGLETON,

Plaintiff,

vs. CASE NO.: 

MIAMI-DADE COUNTY, FLORIDA,

Defendant. 

______________________________/

COMPLAINT AND DEMAND FOR JURY TRIAL

Plaintiff, GLENDA SINGLETON (“SINGLETON”), sues Defendant, MIAMI-DADE

COUNTY, FLORIDA (“COUNTY”), and in support thereof states:

JURISDICTION AND PARTIES

1. This action seeks damages for violations of Title VII of the Civil Rights Act of

1964, 42 USC § 2000e et seq.

2. This claim arose in Miami-Dade County and thus venue is appropriate in this

Court.

3. Plaintiff, GLENDA SINGLETON, is a female and at all times material hereto

was employed by the Defendant, COUNTY, as an Correctional Sergeant in Defendant’s

Department of Corrections & Rehabilitation. She was initially hired by Defendant on or

about September 30, 1991.

4. Defendant, COUNTY, is a political subdivision of the State of Florida, and

within the jurisdiction of this Court.

5. Declaratory, injunctive, equitable relief, lost wages, salary, employment

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benefits and other compensatory damages are sought pursuant to 42 U.S.C. § 12117 and

42 U.S.C. 2000e-5. Costs and attorney’s fees may also be awarded pursuant to 42 U.S.C.

§ 2000e-5(k).

6. Jurisdiction is conferred on this Court by Title 28 U.S.C. § 1331 and 2343(4)

and 42 USC § 2000e-5(f). 

7. Plaintiff has exhausted any and all available administrative remedies or doing

so would be futile. Plaintiff previously filed a Charge of Discrimination with the Equal

Employment Opportunity Commission. Plaintiff’s Dismissal and Notice of Rights were

issued on June 22, 2022, a copy of which is attached hereto as Exhibit “A”.

VIOLATION OF THE CIVIL RIGHTS ACT OF 1964

Sex Discrimination

8. Plaintiff repeats and realleges paragraphs 1 through 7 as if stated fully herein.

9. Defendant maintains certain positions/assignments with the Defendant’s

Corrections & Rehabilitation Department as “specialty positions” which carry additional

responsibilities and are favorable assignments. These positions require an application and

interview process in order to be selected based on rankings.

10. In 2019, Plaintiff applied for a specialty position in the Court Services Bureau

of the Defendant’s Corrections & Rehabilitation Department and as a result of the process,

she was ranked second. The position was offered to the first ranked candidate, a male

employee, and he declined the position. Defendant then bypassed Plaintiff and offered the

position to the candidate ranked third, another male employee. The third ranked candidate

then declined the position. Defendant then failed or refused to offer the position to Plaintiff,

a female. It is significant to note that the fourth candidate, also a female, was not offered

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the position either. Rather than fill the position with a female, Defendant left the position

vacant.

11. There was no valid justification for Defendant’s failure to fill the position with

Plaintiff who had been deemed qualified, interviewed and ranked second on the interview

list.

12. As a result, Plaintiff has been subjected to discrimination on the basis of her

sex in violation of Title VII.

13. As a direct and proximate result of the foregoing, Plaintiff has suffered, is now

suffering, and will continue to suffer, emotional pain and mental anguish. As a direct and

proximate result of such actions, Plaintiff has been, is being and will in the future, be

deprived of income in the form of wages and of prospective benefits due to the Plaintiff

solely because of Defendant’s conduct.

WHEREFORE, Plaintiff demands judgment for damages against Defendant,

including but not limited to the following:

a. a declaration that the acts and practices complained of herein are in violation

of Title VII;

b. enjoining and permanently restraining these violations of Title VII;

c. directing Defendant to place Plaintiff in the position she would have occupied

but for Defendant’s discriminatory treatment of her, and making her whole for all earnings

and other benefits she would have received but for Defendant’s discriminatory treatment,

including but not limited to wages, pension, and other lost benefits;

d. compensatory damages for past, present and future mental anguish, pain and

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suffering, and humiliation caused by the intentional discrimination;

e. awarding Plaintiff the costs of this action together with reasonable attorney’s

fees, as provided by Title VII;

f. trial by jury; and

g. such other relief as the court deems proper.

DEMAND FOR JURY TRIAL

WHEREFORE, Plaintiff, SINGLETON, submits this demand for jury trial for all issues

triable of right by a jury pursuant to Rule 38, Fed. R. Civ. P.

Respectfully submitted,

TERI GUTTMAN VALDES LLC

Counsel for Plaintiff

1501 Venera Avenue, Suite 300

Coral Gables, Florida 33146

Telephone: (305) 740-9600

By: s/Teri Guttman Valdes

Teri Guttman Valdes

Florida Bar No. 0010741

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