RASOR LAW FIRM, PLLC

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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

SHANNON WOODS, 

CIVIL ACTION NO._______________

Plaintiff, HON. ____________________________

 

 

-vsMICHIGAN DEPARTMENT OF CORRECTIONS;

RYAN JOHNSON; and MONICA BURTON,

Defendants .

James B. Rasor (P43476) Gary Grant (P76261)

Jonathan R. Marko (P72450) Jeanmarie Miller (P44446)

Attorneys for Plaintiff Attorneys for Defendant

RASOR LAW FIRM, PLLC MICHIGAN DEPARTMENT OF

201 E. Fourth Street ATTORNEY GENERAL;

Royal Oak, MI 48067 PUBLIC EMPLOYMENT, ELECTIONS

Phone: (248) 543.9000 & TORT DIVISION

Fax: (248) 543.9050 P.O. Box 30736

E-mail: jrm@rasorlawfirm.com Lansing, Michigan 48909

(517) 373-6434

Email: grantg1@michigan.gov

millerj51@michigan.gov

COMPLAINT AND JURY REQUEST

NOW COMES Plaintiff, Shannon Woods, by and through her attorneys, THE 

RASOR LAW FIRM, PLLC, and for her Complaint and Request for Jury Trial against 

Defendants, state as follows:

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INTRODUCTION

1. This is an action for money damages brought pursuant to Title VII of the 

Civil Rights Act of 1964, §2000e et seq., and 42 U.S.C. §§ 1981 and 1983 for 

employment discrimination. 

2. This Court has jurisdiction as a result of the damages sustained by the 

plaintiff and the amount in controversy in this case is well in excess of this court’s 

jurisdictional threshold. 

3. This lawsuit arises out of events occurring within the City of Detroit, 

County of Wayne, State of Michigan

4. Venue is proper pursuant to 28 U.S.C. § 1391(b) because (1) defendants 

reside and have offices within the district, (2) plaintiff resides in this district, and, (3) the 

events giving rise to plaintiff’s claims occurred, in this district. 

PARTIES

5. Plaintiff Shannon Woods (hereinafter Ms. Woods) is a female citizen and 

resident of Southfield, Michigan, in the Eastern District of Michigan. 

6. Defendant Michigan Department of Corrections (hereinafter “MDOC”) is 

a governmental body of the State of Michigan, created pursuant to the laws of the State of 

Michigan, which, at all relevant times, employed plaintiff in Van Buren, Michigan. The 

MDOC has been plagued with accusations of sexual harassment, race discrimination, 

ineffectiveness and unsafe conditions.

7. Ryan Johnson and Monica Burton were, at all times relevant, employees 

of the MDOC and upon information and belief are employees of the State of Michigan.

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COMMON FACTUAL ALLEGATIONS

8. Plaintiff re-alleges and incorporates by reference the foregoing paragraphs 

as if fully set forth herein. 

9. In April 2011, Ms. Woods was offered a position with the Michigan 

Department of Corrections, Lawton Parole Office, as a parole agent.

10. Plaintiff was subjected to a sexually hostile work environment by coworker Ryan Johnson. 

11. Upon Plaintiff’s hire, Ryan Johnson began to have inappropriate contact 

with her including asking her incessantly to go to lunch, dinner, and drinks. Ms. Wood 

refused. 

12. Ryan Johnson would rub Ms. Wood’s shoulder at work in a sexual 

manner;

13. Mr. Johnson assaulted Ms. Wood by forcibly kissing her at work; 

14. Mr. Johnson would come to Ms. Wood’s desk and sit on her desk with his 

genitals bulging through his crotch and near her; 

15. Mr. Johnson would “pet” Ms. Wood. 

16. In November 2013, Mr. Johnson took out his penis and placed it on top of 

a wine bottle, took a picture of it, and then texted it to Ms. Wood and asked her “did she 

like the picture.”

17. Mr. Johnson would show pictures of women’s breasts on his phone around 

the office; 

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18. Mr. Johnson showed his penis to other women at the office, quipping 

“would you like a bottle of wine.”

19. The MDOC was on notice regarding Mr. Johnson and his propensity for 

this type of behavior. Approximately five years ago, Mr. Johnson exposed his penis to 

coworkers in a car on the way back from an MDOC training. There have been several 

complaints against him. However, due to his status as union steward, and with “friends 

in high places,” the MDOC has failed to take any concrete action against him or to 

protect its female employees from this known predator. 

20. Plaintiff reported Mr. Johnson’s misconduct to MDOC officials. First, she 

reported his actions verbally to her supervisor, specifically Monica Burton. She was not 

protected. 

21. Plaintiff filed a formal discriminatory harassment complaint. The MDOC 

still did not taken formal action; and, Mr. Johnson went to Plaintiff’s office since the 

incident. 

22. Since Plaintiff complained, she has been retaliated against by the MDOC, 

including being subjected a hostile work environment. 

23. Plaintiff was accused of having sex with Mr. Johnson by co-workers. This 

accusation is blatantly untrue. 

24. Plaintiff was refused transfers to another office where she could escape the 

predator.

25. Plaintiff was ostracized by the MDOC, including being called a “snitch” 

for reporting her sexual assault and harassment; 

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26. Plaintiff’s doctors have indicated it would be unsafe for her to return to 

work. 

27. As a result of defendants’ actions, plaintiff has suffered and will continue 

to suffer, including but not limited to:

a. Emotional distress;

b. Loss of personal freedom and liberty;

c. Pain and suffering;

 d. Fright and shock;

 e. Horror, outrage and indignity;

 f. Economic damages including lost wages 

and/or loss of earning capacity;

 g. All other damages allowed under the law;

 h. Punitive damages.

WHERFORE, plaintiff requests that this court enter judgment against 

defendants in whatever amount she may be found to be entitled, together with interest, 

costs, reasonable attorney fees, and such other relief as the court deems just under the 

circumstances. 

COUNT I

VIOLATION OF TITLE VII, § 1981 AND §1983 PROHIBITION

AGAINST EMPLOYMENT DISCRIMINATION 

Disparate Treatment

28. Plaintiff re-alleges and incorporates by reference the foregoing paragraphs 

as if fully set forth herein.

29. This claim is authorized and instituted pursuant to the provisions of Title 

VII of the Civil Rights of 1964, as amended, 42 U.S.C. § 2000e et seq., for relief based 

upon the unlawful employment practices of the Defendant MDOC.

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30. Specifically, Ms. Woods complains of Defendant MDOC violation of 

Title VII’s prohibition against discrimination in employment based, in whole or in part, 

upon an employee’s gender and/or sex. 

31. During her employment with MDOC at Lawton Parole Office, Ms. Woods

was a protected under Title VII against gender and/or sex-based discrimination by her 

employer, Defendant MDOC. 

32. Ms. Woods was therefore treated in a disparate manner and was subjected 

to defendant’s unfair policies and practices insofar as that she was treated in an unequal 

manner and unlike male employees similarly situated with the defendant. 

33. Defendant MDOC, further denied Ms. Woods equal employment 

opportunities because of her gender, i.e. female. 

a. The Defendant did not discipline or discharge similarly situated 

male employees;

b. Ms. Woods had consistently satisfied and or/exceeded all the 

requirements of the position;

c. As a result of Defendant MDOC’s employment policies, 

procedures and practices, Ms. Woods was unjustly and 

discriminatorily deprived of equal employment opportunities 

because of her gender, female. 

34. The above named Defendants’ conduct was a direct and proximate cause 

of the injuries, damages and harm suffered by Ms. Woods. 

35. Furthermore, Defendant MDOC intentionally and/or with reckless 

indifference, engaged in the above stated discriminatory practices against Ms. Woods, 

contrary to Ms. Woods’ federally protected rights as guaranteed to her under Title VII of 

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the Civil Rights Act of 1964, 42 U.S.C. §2000e, et seq., as amended, and 42 

U.S.C.§1981. 

WHERFORE, plaintiff requests that this court enter judgment against defendants

in whatever amount she may be found to be entitled, together with interest, costs, 

reasonable attorney fees, and such other relief as the court deems just under the 

circumstances. 

COUNT II

VIOLATION OF TITLE VII, 1981AND 1983 PROHIBITION 

AGAINST EMPLOYMENT DISCRIMINATION 

Hostile Work Environment

36. Plaintiff re-alleges and incorporates by reference the foregoing paragraphs 

as if fully set forth herein.

37. This claim is authorized and instituted pursuant to the provisions of Title 

VII of the Civil Rights of 1964, as amended, 42 U.S.C. § 2000e et seq., for relief based 

upon the unlawful employment practices of the Defendant MDOC.

38. Specifically, Ms. Woods complains of Defendant MDOC violation of 

Title VII’s prohibition against discrimination in employment based, in whole or in part, 

upon an employee’s gender and/or sex. 

39. During her employment with MDOC at Lawton Parole Office, Ms. Woods

was a protected under Title VII against gender and/or sex-based discrimination by her 

employer, Defendant MDOC. 

40. Mr. Johnson was not terminated or reprimanded for his infractions of 

MDOC policy. 

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41. Ms. Woods was therefore treated in a disparate manner and was subjected 

to defendant’s unfair policies and practices insofar as that she was treated in an unequal 

manner and unlike male employees similarly situated with the defendant. 

42. The unwelcome conduct affected a term or condition of employment 

and/or had the purpose or effect of unreasonably interfering with plaintiff’s work 

performance and/or creating an intimidating, hostile or offensive work environment.

43. Defendant MDOC, further denied Ms. Woods equal employment 

opportunities because of her gender, i.e. female. 

a. The Defendant did not discipline or discharge similarly situated 

male employees;

b. Ms. Woods had consistently satisfied and or/exceeded all the 

requirements of the position;

c. As a result of Defendant MDOC’s employment policies, 

procedures and practices, Ms. Woods was unjustly and 

discriminatorily deprived of equal employment opportunities 

because of her gender, female. 

44. The above named Defendants’ conduct was a direct and proximate cause 

of the injuries, damages and harm suffered by Ms. Woods. 

45. Furthermore, Defendant MDOC intentionally and/or with reckless 

indifference, engaged in the above stated discriminatory practices against Ms. Woods, 

contrary to Ms. Woods’ federally protected rights as guaranteed to her under Title VII of 

the Civil Rights Act of 1964, 42 U.S.C. §2000e, et seq., as amended, and 42 

U.S.C.§1981. 

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WHERFORE, Plaintiff requests that this court enter judgment against defendants

in whatever amount she may be found to be entitled, together with interest, costs, 

reasonable attorney fees, and such other relief as the court deems just under the 

circumstances. 

Respectfully submitted,

/s/ Jonathan R. Marko

_______________________

Jonathan R. Marko (P72450)

Attorney for Plaintiff

THE RASOR LAW FIRM, PLLC

201 East Fourth Street

Royal Oak, Michigan 48067

Dated: January 24, 2015 (248) 543-9000

JURY DEMAND

NOW COMES, Plaintiff Shannon Woods, by and through her attorneys, THE 

RASOR LAW FIRM PLLC, and hereby demands a trial by jury. 

Respectfully submitted,

/s/ Jonathan R. Marko

_______________________

Jonathan R. Marko (P72450)

Attorney for Plaintiff

THE RASOR LAW FIRM, PLLC

201 East Fourth Street

Royal Oak, Michigan 48067

Dated: January 24, 2015 (248) 543-9000

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