UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

BRIAN WRIGHT,

Plaintiff

v. CASE NO. 0:22-cv-62386-WPD

SIXT RENT A CAR, LLC,

Defendant.

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AMENDED COMPLAINT

Plaintiff, BRIAN WRIGHT (“WRIGHT”), by and through undersigned 

counsel, files this action against Defendant SIXT RENT A CAR, LLC (“SIXT”), 

and hereby alleges as follows:

NATURE OF THE CASE

1. This is a 42 U.S.C. §1981 claim arising out of racial discrimination 

against Plaintiff Wright by Defendant Sixt, and deprivation of Plaintiff’s contractual 

rights by Defendant.

JURISDICTION, VENUE, AND PARTIES

2. Jurisdiction. This Court has original jurisdiction over Plaintiff’s Section 

1981 claims pursuant to 28 U.S.C. §§1331 and 1343(a)(4) and this involves a federal 

question regarding the deprivation of Plaintiff’s rights under Section 1981.

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3. Venue. Venue is proper in this District pursuant to 28 U.S.C. §1391(b) 

because a substantial part of the events or omissions giving rise to this action 

occurred in this district.

4. At all times material, Plaintiff was a resident of Fort Lauderdale, 

Broward County, Florida.

5. Defendant is a foreign limited liability company authorized to do 

business in Florida, with a principal place of business located at 1501 NW 49th St., 

Suite 100, Fort Lauderdale, FL 33309.

6. Defendant is subject to personal jurisdiction in this District because it 

maintains facilities and business operations in this District and committed the 

discriminatory acts alleged herein occurred in this District.

7. Defendant Sixt is a limited liability company in the business of 

providing short term car rentals, with a principal place of business located in Fort 

Lauderdale, Florida.

8. Plaintiff Wright entered into a contract with Defendant Sixt, to rent a 

car.

9. All conditions precedent to maintaining this action have been satisfied 

by Plaintiff or have been excused or waived by Defendants.

GENERAL ALLEGATIONS

10. Plaintiff Wright is an African American male.

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11. On February 6, 2022, Plaintiff Wright entered into a contract to rent a 

small SUV from Defendant Sixt, for a term of one week starting February 6, 2022, 

through February 13, 2022.

12. Plaintiff Wright had rented cars from Sixt Rent a Car numerous times 

prior to the February 6, 2022, rental contract.

13. When Plaintiff Wright arrived at the Sixt Rent a Car location in Fort 

Lauderdale to pick up his car, he was informed that because there were no small 

SUV’s available, he would be provided a complimentary upgrade to a luxury SUV.

14. On February 8, 2022, Plaintiff Wright received a phone call from the 

Fort Lauderdale branch manager of Defendant Sixt, Mr. Brennon Sparke. 

15. On that date Mr. Sparke informed the Plaintiff that the rate he was 

paying for the SUV was too low, and he could not keep the vehicle, nor extend the 

contract, and the vehicle needed to be returned immediately.

16. During said call, Plaintiff Wright explained to Mr. Sparke that he was 

given a luxury SUV because Sixt did not have vehicles available in the size he 

reserved. Plaintiff asked why he could not keep the vehicle for the end of his oneweek contract term, to which Mr. Sparke rudely responded, “because you can’t,” 

and abruptly ended the call.

17. Following his phone call with Mr. Sparke, Plaintiff visited the Sixt 

location in Fort Lauderdale. There, Plaintiff spoke with Shawn, a rental agent, who 

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informed Plaintiff he could keep the luxury SUV due to a vehicle shortage. Shawn 

extended the rental contract to a return date of March 6, 2022.

18. On February 17, 2022, Plaintiff received another phone call from Mr. 

Sparke. 

19. Mr. Sparke, in an unpleasant tone, asked Plaintiff why the SUV he 

rented had not been returned. Plaintiff patiently explained that he tried to return the 

vehicle, but due to a vehicle shortage, his contract for the SUV rental was extended.

20. During the February 17, 2022, phone call with Mr. Sparke, Plaintiff was 

at work, and answered the call on speakerphone.

21. Upon Plaintiff informing Mr. Sparke that he had not returned the 

vehicle due to the vehicle shortage, and because his contract was not up, Mr. Sparke 

stated: “You Black—You people can’t rent nice cars and pay a cheap rate.”

22. Plaintiff and his co-workers heard the racial slur made by Mr. Sparke 

over the phone. Plaintiff Wright, fittingly, lodged a complaint against Mr. Sparke 

with Sixt Rent a Car.

23. On March 6, 2022, Plaintiff visited the Sixt location in Fort Lauderdale 

to return the vehicle pursuant to his contract. There he was informed that the contract 

terms were altered without his consent, and that the new drop off location for his 

vehicle was Orlando, not Fort Lauderdale.

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24. Plaintiff learned from a rental agent that Sixt manager Mr. Sparke 

altered the rental contract to reflect a different drop off location, imposed a fee due 

to the car being returned to a different location, and placed Plaintiff on a “Do Not 

Rent” list.

25. Plaintiff also learned that Mr. Sparke himself “closed out” the 

complaints that Plaintiff lodged against him for Sparke’s improper and unlawful 

conduct.

26. After Defendant Sixt failed to address the complaints made by Plaintiff; 

Plaintiff reached out to several branch managers of Sixt Rent a Car in different 

locations, one of whom stated that Plaintiff’s complaints were “probably going to be 

pushed aside with no action.”

27. On March 23, 2022, Plaintiff received a phone call from Sixt area

manager, Ms. Natalie Hernandez.

28. During said call, Ms. Hernandez stated that Plaintiff’s complaint was 

“not as serious as he was making it out to be.”

29. On April 8, 2022, Plaintiff received a phone call from the Vice 

President and Area Director of Defendant Sixt, Ms. Monique Kennedy. Ms. 

Kennedy failed to address any disciplinary action against Mr. Sparke or others, to 

redress the situation.

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30. The Fort Lauderdale Sixt Rent a Car location is replete with negative 

reviews online.

31. Plaintiff has been required to retain the undersigned counsel to 

represent him in this action and is obligated to pay a reasonable fee for their services.

COUNT I

VIOLATION OF 42 U.S.C. §1981

32.Plaintiff repeats and realleges and incorporates by reference the allegations 

set forth in paragraph 1 through 31, inclusive, as though fully set forth herein.

33.Plaintiff Wright is African American and therefore a member of a racial 

minority.

34.Defendant Sixt, via its employees, intended to and did discriminate against 

Plaintiff Wright based solely on his race.

35.Defendant has discriminated against Plaintiff in violation of the Federal Civil 

Right Statute, 42 U.S.C. §1981.

36.By the conduct described above, Defendant Six t intentionally deprived 

Plaintiff of the same rights as are enjoyed by white citizens to the creation, 

performance, enjoyment, and all benefits and privileges, of their contractual 

relationship with Defendant, in violation of 42 U.S.C. §1981.

37.Such discrimination would not have occurred but for Plaintiff’s race, as 

evidenced by the Defendant’s comments and treatment of Plaintiffs versus the 

treatment of other white customers.

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38.As a result of Defendant’s discrimination in violation of Section 1981, 

Plaintiff has been denied contractual rights, benefits, and privileges and has suffered 

anguish, humiliation, distress, inconvenience and loss of enjoyment of life, thereby 

entitling him to equitable monetary relief, as well as compensatory damages.

39.Defendant, in its discriminatory actions, has acted with malice or reckless 

indifference to Plaintiff’s rights, thereby entitling him to an award of punitive 

damages.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays that the Court enter judgment in their favor 

and against Defendant, containing the following relief:

A. An award of damages in an amount to be determined at trial, plus 

prejudgment interest, to compensate Plaintiff for all monetary and/or 

economic damages;

B. An award of damages in an amount to be determined at trial, plus 

prejudgment interest, to compensate Plaintiff for all non-monetary and/or 

compensatory damages, including, but not limited to, compensation for his 

mental anguish and emotional distress, humiliation, embarrassment, stress 

and anxiety, loss of self-esteem, self-confidence and personal dignity, and 

emotional pain and suffering and any other physical or mental injuries;

C. An award of damages for any and all other monetary and/or non-monetary 

losses suffered by Plaintiff in an amount to be determined at trial, plus 

prejudgment interest;

D. An award of punitive damages;

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E. An award of costs that Plaintiff has incurred in this action, as well as 

Plaintiff’s reasonable attorneys’ fees to the fullest extent permitted by law; 

and

F. Such other and further relief as this Court may deem just and proper.

JURY DEMAND

Plaintiff hereby demands a trial by jury on all issues of fact and damages stated 

herein.

Dated this April 26 2023. 

BLACK ROCK TRIAL LAWYERS, PLLC

By: ________________________________

Gil Sanchez, Esq.

Counsel for Plaintiff

Florida Bar Number: 735981

201 S. Westland Ave.

Tampa, Florida 33606

(813) 254-1777 Office

(813) 254-3999 Fascimile

gil@blackrocklaw.com

litigaton@blackrocklaw.com

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