PLAINTIFF’S ORIGINAL COMPLAINT PAGE 1

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

CHANTOVIA JACKSON,

Plaintiff,

vs.

CHICK AND SEAFOOD INC., and LINDA 

HENDERSON, an Individual.

Defendants.

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CIVIL ACTION NO. ___________

PLAINTIFF’S ORIGINAL COMPLAINT

COMES NOW Plaintiff Chantovia Jackson (“Jackson” or “Plaintiff”) and files her 

Original Complaint and, in support of her causes of action, alleges as follows:

I. PARTIES

1. Plaintiff is a resident of and citizen of the state of Texas. 

2. Plaintiff is an African-American female.

3. Defendant Chick and Seafood Inc. (“CSI”) is a Texas corporation with its 

principal place of business in Duncanville, Dallas County, Texas. 

4. Defendant Linda Henderson (“Henderson”) is an individual resident and citizen of 

Texas.

II. JURISDICTION AND VENUE

5. This action arises under United States Code, Title 42, § 1981 et seq. and Title VII, 

42 USC § 2000e et seq.

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6. Venue properly lies in this Court because all acts and omissions giving rise to this 

claim (specifically the employment decisions addressed herein) took place in Dallas County, 

which is in the District and Division in which suit has been filed.

III. FACTS SUPPORTING PLAINTIFF’S CLAIMS

7. CSI operates a fast-food franchise outlet of Henderson Chicken on Camp Wisdom 

Road in Dallas, Texas. The Camp Wisdom Henderson Chicken location is one of multiple 

Henderson Chicken franchises throughout the Dallas area. 

8. Ms. Henderson is the franchisor of Henderson Chicken. All of the Henderson 

Chicken franchises’ operations are interrelated, with centralized control of labor relations, 

including transferring employees between and among the franchises. Ms. Henderson participates 

in the management and oversight of CSI and the other Henderson Chicken franchises and 

exercises financial control. 

9. Between approximately 2014 and 2021, Plaintiff worked at several Henderson 

Chicken franchise locations in the Dallas-Fort Worth area. Sometime in 2018, Plaintiff began 

working at the Camp Wisdom Road location of Henderson Chicken (the “Camp Wisdom 

Store”).

10. Plaintiff discovered that the atmosphere at the Camp Wisdom Store was unusual. 

The Camp Wisdom Store employed a number of non-United States citizens who were not 

authorized to work in the United States. Many of these employees used fictitious names or 

aliases in connection with their work at the restaurant.

11. Furthermore, the purported owner, who used the name “Jim,”1 frequently stated 

his belief that African-Americans are lazy and not hard workers. Both Jim and the store manager, 

who used the name “Jordan,” regularly referred to African-American employees as “you people” 

1 Plaintiff intends to name “Jim” as an individual defendant once she learns his true identity. 

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and “you motherfuckers.” African-American employees were frequently denied breaks, while 

non-African-American employees essentially were free to come and go as they pleased. 

12. In addition to the racial bias exhibited by the Camp Wisdom Store’s management, 

“Jim” and “Jordan” both acted in a manner that was sexually inappropriate. “Jordan” 

inappropriately touched female African-American employees, including Plaintiff. Specifically, 

“Jordan” touched Plaintiff’s buttocks on more than one occasion. Another time, “Jordan” 

attempted to put money into Plaintiff’s bra. 

13. On another occasion, “Jim” offered Plaintiff $10,000 to marry “Jordan” so that 

“Jordan” could obtain United States citizenship by virtue of the marriage. Such actions would 

constitute immigration fraud in violation of 18 U.S.C. §§ 1001 and 1546. Plaintiff refused the 

illegal offer.

14. Plaintiff complained about these actions to Jim, who failed and refused to do 

anything to address the issue. Plaintiff next complained to Ms. Henderson. Like “Jim,” Ms. 

Henderson failed and refused to take any action to address these issues.

15. Shortly after Plaintiff complained to Ms. Henderson, “Jim” terminated her 

employment, explaining that Plaintiff complains too much. 

IV. STATEMENT OF CLAIMS

COUNT ONE: RETALIATION UNDER SECTION 1981

16. Plaintiff incorporates Paragraphs 1 through 15 hereinabove as if fully set forth 

herein at length.

17. 42 U.S.C. § 1981 prohibits retaliation when an employee complains of race 

discrimination. 

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18. Plaintiff complained to both “Jim” and Ms. Henderson about racially offensive 

language and disparate treatment and received no substantive response. 

19. After Plaintiff complained, Defendants terminated her employment, expressly 

because of her complaints of employment discrimination. 

20. As a result of Defendants’ actions, Plaintiff suffered and continues to suffer 

damages and Plaintiff hereby sues. 

21. Plaintiff further requests her attorneys’ fees. 

COUNT TWO: DISCRIMINATION IN VIOLATION OF TITLE VII

22. Plaintiff incorporates Paragraphs 1 through 21 hereinabove as if fully set forth 

herein at length.

23. 42 U.S.C. § 2000e prohibits discrimination against employees based upon their 

race and gender, among other things. 

24. Defendants discriminated against Plaintiff based upon both her race and gender. 

25. Employees of Defendant CSI regularly used derogatory and insulting language in 

reference to African-American persons and denied African-American employees breaks and 

other benefits of employment that were provided to employees of other races. 

26. Employees of Defendant CSI also regularly acted in a sexually inappropriate 

manner, including touching Plaintiff and other female employees inappropriately and offering 

Plaintiff money to marry another employee for citizenship purposes.

27. The actions of CSI employees described above constituted unwelcome 

harassment based upon Plaintiff’s membership in one or more protected groups (race and 

gender) and was sufficiently pervasive to affect a term, condition, or privilege of employment.

28. Plaintiff complained about this behavior and received no substantive response. 

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29. As a result of Defendants’ actions, Plaintiff suffered and continues to suffer 

damages and Plaintiff hereby sues.

COUNT THREE: RETALIATION IN VIOLATION OF TITLE VII

30. Plaintiff incorporates Paragraphs 1 through 29 hereinabove as if fully set forth 

herein at length.

31. 42 U.S.C. § 2000e prohibits retaliation against employees who complain about 

illegal employment discrimination under Title VII. 

32. Plaintiff complained to both “Jim” and Ms. Henderson about the unlawful 

discrimination she suffered.

33. Neither Jim nor Ms. Henderson did anything to correct their own and their 

employees’ offensive behavior. 

34. Instead, CSI terminated Plaintiff’s employment. At the time of her termination, 

“Jim” told Plaintiff that she was being terminated because of her complaints. 

35. As a result of Defendants’ actions, Plaintiff suffered and continues to suffer 

damages and Plaintiff hereby sues.

36. Plaintiff also seeks her attorneys’ fees.

V. REMEDIES

WHEREFORE, Plaintiff prays that the Court grant her the following relief:

a. Back pay and front pay in a precise amount to be determined by the jury;

b. Compensatory damages against Defendants as a consequence of Defendants’

unlawful actions, in a precise amount to be determined by the jury;

c. Punitive and exemplary damages, in a precise amount to be determined by the 

jury;

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d. Prejudgment and post-judgment interest;

e. Reasonable attorneys' fees, expenses and costs, as specifically authorized by 

statute, to be calculated by the Court pursuant to the established procedures and 

precedents; and

f. Such other relief as the Court shall deem just and proper.

VI. JURY TRIAL DEMAND

Plaintiff demands a trial by jury on all issues of facts and damages raised in this case.

Respectfully submitted,

Michael E. Coles

State Bar No. 24007025

mikec@colesfirm.com

THE COLES FIRM PC

4925 Greenville Ave., Suite 200

Dallas, Texas 75206

(214) 443-7860 (Telephone)

(972) 692-7145 (Facsimile)

Of Counsel:

THE LAMBERSON LAW FIRM PC

 6333 E. Mockingbird Ln, Suite 147-524

Dallas, Texas 75214

 (214) 320-2894 (Telephone)

 (214) 602-5796 (Facsimile)

By: ____________________________________

Elizabeth Aten Lamberson, Lead Attorney

State Bar No. 24027044

lizl@colesfirm.com

ATTORNEYS FOR PLAINTIFF

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