PLAINTIFF’S ORIGINAL COMPLAINT PAGE 1

IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

BETH NIKOPOULOS, §

Plaintiff, §

 §

vs. § CIVIL ACTION NO. ___________

 §

DALLAS COLLEGE, §

Defendant. §

PLAINTIFF’S ORIGINAL COMPLAINT

Plaintiff Beth Nikopoulos (“Plaintiff” or “Ms. Nikopoulos”) files this Original Complaint, 

complaining of Defendant, Dallas College (“DC”), and in support thereof, would respectfully show 

the Court as follows:

INTRODUCTION

Beth Nikopoulos was the Director of Student Life for all DC, until she was terminated 

without warning, without good cause, without written notice of the accusations against her, and 

without a hearing. 

DC deprived Ms. Nikopoulos of not only her employment, but of her Fifth and Fourteenth 

Amendment rights to procedural and substantive due process, in violation of DC’s own policies 

and the Constitution of the United States, as well as her Thirteenth and Fifteenth Amendment rights 

against discrimination on the basis of her race and/or skin color. DC fired Ms. Nikopoulos during 

the term of a written one-year contract, without providing any procedural due process prior to the 

effective date of termination and without good cause. Indeed, they have still not provided any 

procedural due process, in violation of their own policies, which require them to give an employee 

“reasonable notice in writing” of the grounds for dismissal before the employee is dismissed, and 

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to make a determination of good cause “prior to dismissal.” In firing Ms. Nikopoulos, DC, its Vice 

Chancellor, and Dean of Students deprived Ms. Nikopoulos of her Fifth and Fourteenth 

Amendment rights to procedural and substantive due process. 

As part of her duties and responsibilities as the Director of Student Life, Ms. Nikopoulos

oversaw all student clubs and organizations, the student government association, student 

leadership development, and the DC TEDx program. She was also in charge of submitting 

purchase orders for student clubs and organizations to the business procurement office for 

approval. As part of this process, Ms. Nikopoulos is required to write a memo accompanying the 

request for the business procurement office to provide funds for the requested purchase. This is a 

task that Ms. Nikopoulos has been performing, and performing in an exemplary manner, for more 

than a decade. 

DC is going through a re-accreditation process. There have been some bumps along the 

way, including with the business procurement office processing requests for payment. Ms. 

Nikopoulos submitted two requests for payment to the business procurement office. Unbeknownst 

to Ms. Nikopoulos, the business procurement office rejected these requests for payment because 

the accompanying memo was not correct, even though it had to be approved by the very same 

people who had to authorize its release to the business procurement office.

On August 1, 2022, Ms. Nikopoulos was unceremoniously called to a meeting in the office 

of the President of the Eastfield campus. When Ms. Nikopoulos arrived, she met with Ms. Aguilar 

and Dr. Rebecca Tuerk (“Dr. Tuerk”), Senior Director of Title IX & Employee Relations. In this 

meeting, Ms. Aguilar and Dr. Tuerk informed Ms. Nikopoulos that she violated procurement 

procedures and that she had been violating procurement procedures since 2009, well over a decade 

ago. Based upon these alleged violations of the procurement procedures – without any prior 

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notification (for over a decade), without any substantiating evidence – Ms. Aguilar and Dr. Tuerk 

fired Ms. Nikopoulos. 

Ms. Nikopoulos brings this lawsuit to remedy these violations of her rights, as set forth 

below. 

I. JURISDICTION AND VENUE

1. This Court has jurisdiction over this case pursuant to 28 U.S.C. §§ 1331, 1343 and 

1367; 42 U.S.C. § 1983; and the Fifth and Fourteenth Amendments to the United States 

Constitution. Venue is proper in this district pursuant to 28 U.S.C. § 1391(b), as all or a substantial 

part of the events giving rise to Plaintiffs’ claims occurred in this district.

2. Pursuant to 42 U.S.C § 1983, Plaintiff alleges herein one or more ongoing 

violations of federal law, and seeks prospective relief, declaratory and injunctive, against a state 

actor in their official capacities. 

II. PARTIES

3. Plaintiff, Beth Nikopoulos, is a Texas citizen, resides in Denton/Collin County, 

Texas, and at all relevant times was employed by DC in Dallas County, Texas, 

4. Defendant, Dallas County Community College District, is a community college 

district organized and existing pursuant to the laws of the State of Texas for the purpose of 

operating a system of community colleges in and around Dallas County, Texas. Also, DC is a 

“state actor” within the meaning of the United States Constitution and the actions complained of 

herein comprise “state action,” and were taken under color of law. The address of DC’s 

administrative offices is 1601 Botham Jean Blvd., Dallas, Dallas County, Texas 75215. DC may 

be served with process by serving its Chancellor, Dr. Justin Lonon., at the foregoing address.

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III. FACTUAL BACKGROUND

5. Plaintiff, Beth Nikopoulos, worked for DC for twenty-four (24) years. Ms. 

Nikopoulos was the Director of Student Life for DC. Ms. Nikopoulos was sent to the Eastfield 

campus on or around July 18, 2022, when Ms. Aguilar informed her the Eastfield campus needed 

a lot of help. Ms. Nikopoulos took that position with pride wanting to help turn around the Eastfield 

campus for the better. Ms. Nikopoulos always enjoyed the support of her supervisors, with 

outstanding performance reviews. At the time of her firing, Ms. Nikopoulos was employed 

pursuant to a one-year contract, which had not yet expired. 

6. In spring of 2022, Ms. Nikopoulos oversaw the procurement of several trips 

organized for the student government association and other student clubs. She submitted her 

memos and receipts to the business procurement office for processing; however, through no fault 

of her own, the requests for payment sat in the business procurement office without being reviewed 

for months. 

7. Ms. Nikopoulos informed her direct supervisor, Ms. Aguilar, about the issues and 

delays being experienced in the business procurement office relating to the payment applications 

she submitted. However, Ms. Nikopoulos was informed she must take personal responsibility for 

the failures associated with these payment applications to the business procurement office even 

though the entire system was failing due to the staffing issues surrounding the re-hiring process 

associated with the re-accreditation process of DC. 

8. Although Ms. Aguilar knew of the issues, not attributable to Ms. Nikopoulos, with 

the business procurement office, Ms. Aguilar still made the decisions to terminate Ms. 

Nikopoulos’s employment. Other employees, in similar positions to Ms. Nikopoulos, have also 

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experienced the growing pains of re-accreditation with the business procurement office; however, 

none of those employees have suffered the same fate as Ms. Nikopoulos.

9. Additionally, Ms. Nikopoulos was targeted by Dr. Beatriz Joseph (“Dr. Joseph”), 

Vice Chancellor of Student Success, and Cynthia Aguilar, Dean of Students and Student 

Engagement (“Ms. Aguilar”) for termination because Ms. Nikopoulos routinely pushed back on 

illegal actions Dr. Joseph wanted to take. For example, Ms. Aguilar approached Ms. Nikopoulos

asking her to change the student government association’s bylaws. However, that cannot be done 

because the student government controls their own bylaws and because it must be done through a 

vote of the student government association. When Ms. Nikopoulos pointed this out to Ms. Aguilar, 

and in other similar circumstances, Ms. Aguilar directed Ms. Nikopoulos to do it anyway because 

“this is what Dr. Joseph wants.”

10. Ms. Nikopoulos pushed back on these illegal requests because she was protecting 

not only herself, but also Dr. Joseph, Ms. Aguilar, and DC altogether. Yet, despite her 

unquestionable ethics, Ms. Nikopoulos was targeted for termination through the guise of violating 

procurement procedures without being given prior notice, without being given the opportunity for 

a hearing, and without having any evidence presented to her about her alleged wrongdoing.

11. It is also important to note that Dr. Joseph was previously the President of the 

Mountainview campus. While there, Dr. Joseph worked with Ms. Aguilar, and other deans and 

associate deans who now have positions in DC administration. Furthermore, Dr. Joseph, Ms. 

Aguilar, and the other employees are all Hispanic. They formed a clique at the Mountainview 

campus, and this has carried over to DC administration to the exclusion of those not within their 

clique.

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12. Ms. Nikopoulos was targeted for termination in direct violation of her Fifth and 

Fourteenth Amendment rights to procedural and substantive due process because Dr. Joseph and 

Ms. Aguilar, acting under color of law, discriminated against her based upon her race because she 

did not fit in with their clique and used the alleged violations of procurement procedures as the 

springboard to conduct their illegal acts. 

IV. CAUSES OF ACTION

13. Alternative Pleadings. To the extent necessary, each of the claims set forth below 

is pleaded in the alternative.

Count 1: Violation of 42 U.S.C. § 1983 

14. 42 U.S.C. § 1983 prohibits Defendant from depriving Plaintiff of her rights, 

privileges, and/or immunities secured under the United States Constitution. All the wrongful 

conduct by Defendant, as described herein, is a result of the policies of Defendant DC, as written 

and/or as applied to Plaintiff. Additionally, all the wrongful conduct described herein was caused 

by policymakers of Defendant DC, including Dr. Joseph and Ms. Aguilar, and their conduct was 

sanctioned, through action and/or inaction, by DC’s Board of Trustees, Dr. Joseph and Ms. 

Aguilar, and others, all singularly or collectively acting as policymakers for Defendant DC in this

case.

Count 2: Violations of the United States Constitution, Fifth and Fourteenth 

Amendments: Procedural and Substantive Due Process. 

15. As set forth above, Defendant deprived and/or improperly diminished Plaintiff’s

right to procedural and substantive due process, as secured by the Fifth and Fourteenth 

Amendments to the United States Constitution. 

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16. Defendant violated Plaintiff’s right to procedural due process by failing and/or 

refusing to conduct, or even attempt to conduct, a thorough and timely investigation into the 

allegations and accusations made against Plaintiff that formed the basis of her termination, and 

such failure and/or refusal included not questioning or interviewing Plaintiff. Defendant never 

provided Plaintiff with the reasons she was being terminated before terminating her, in violation 

of DC policy and in violation of Plaintiff’s constitutional rights

17. Defendant’s actions deprived Plaintiff of her property interest in her employment 

contract, and in her liberty interest in her good name. 

18. Additionally or alternatively, Defendant violated Plaintiff’s right to procedural due 

process by failing and/or refusing to provide Plaintiff with a full due process hearing prior to her

termination, depriving and/or improperly diminishing: (1) Plaintiff’s protected rights under the 

Fifth and Fourteenth Amendments; (2) Plaintiff’s protected liberty interest in her good name and 

reputation, as well as her ability to pursue her chosen profession; (3) Plaintiff’s protected property 

interest in her employment contract, her performance thereof, and her rights thereunder; (4) 

Plaintiff’s protected property interest in DC’s policies, procedures, guidelines, rules, and/or 

regulations; and (5) Plaintiff’s right to be free from retaliation for exercising such protected rights. 

Defendant impinged, deprived, and/or improperly diminished all of Plaintiff’s foregoing protected 

interest and freedoms without due process of law. 

19. Additionally, or alternatively, Defendant violated Plaintiff’s right to procedural due 

process by preventing her any meaningful opportunity to be heard. Defendant failed and/or refused 

to provide Plaintiff with the minimal procedural due process and/or the procedural redress system 

incorporated into DC’s policies, procedures, guidelines, rules, and/or regulations, effectively 

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denying Plaintiff the due process rights to which she was entitled, thus, violating her right to 

procedural due process guaranteed by the United States Constitution. 

20. Additionally, Plaintiff possesses a claim against Defendant for violation of 

substantive due process for Defendant’s arbitrary, capricious, unreasonable, and/or irrational 

actions against taken her, as set forth in more detail above. Additionally, or alternatively, Plaintiff 

has been deprived of her protected and fundamental rights without due process of law in an 

arbitrary, capricious, unreasonable, and/or irrational manner. 

21. Defendant’s actions and/or conduct further constitute a deprivation of due process, 

as each and all of the above acts and/or omissions were made in recognition of, as a part of, and/or 

as a result of the policies, practices, and/or customs of DC, created by or through policymakers 

and/or persons to whom Defendant DC effectively delegated policymaking authority. 

22. Defendant’s conduct constitutes violations of Plaintiff’s rights to procedural and 

substantive due process. As a result of Defendant’s conduct, Plaintiff has been injured and/or 

damaged. Dr. Joseph and Ms. Aguilar purported to be acting under color of law and were state 

actors within the meaning of the Fourteenth Amendment of the Constitution of the United States. 

Their actions were arbitrary and capricious, manifestly unjust and were clear violations of clearly 

established constitutional and statutory law.

23. Accordingly, Plaintiff seeks to recover her damages from Defendant in an amount 

that is within the jurisdictional limits of this Court and to recover any and all other remedies 

afforded and/or available under law and/or in equity, including but not limited to injunctive relief, 

equitable relief, and her attorneys’ fees and costs.

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Count 3: Racial Discrimination in Violation of the Thirteenth and Fifteenth 

Amendments

24. As described above, Defendant’s conduct equates to racial discrimination in 

violation of the thirteenth and fifteenth amendments of the United States Constitution because Ms. 

Nikopoulos was discriminated against on the basis of her skin color. Dr. Joseph and Ms. Aguilar, 

being part of the same clique of Hispanic administrators that formed at the Mountainview campus 

and migrated to DC administration, discriminated against Ms. Nikopoulos because she is White 

and did not fit in with their clique.

25. Ms. Nikopoulos was terminated on the basis of her skin color and not on the basis 

of the alleged violations of procurement procedures, which attempts to give color of law to the 

illegal termination of Ms. Nikopoulos.

26. Accordingly, Plaintiff seeks to recover her damages from Defendant in an amount 

that is within the jurisdictional limits of this Court and to recover any and all other remedies 

afforded and/or available under law and/or in equity, including but not limited to injunctive relief, 

equitable relief, and her attorneys’ fees and costs.

Count 4: Racial Discrimination in Violation of Title VII

27. The conduct described herein is violative of both Title VII. After submitting to the 

EEOC/TWC her complaint and after receiving a right a right to sue letter, Plaintiff will ask the 

court for leave to amend to include those causes in this suit, as well.

Count 5: Pendent State Law Claim for Breach of Contract

28. As set forth above, Defendant DC breached Plaintiff’s employment contract by 

failing and/or refusing to abide by and/or comply with the terms thereof. DC’s policies, 

procedures, guidelines, rules, and/or regulations, which are incorporated into and made a part of 

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Plaintiff’s employment with DC, provide express contractual terms regarding Plaintiff’s 

employment, including its term. DC breached Plaintiff’s employment contract by terminating such 

contract during its term without good cause, and by not adhering to its own policies, procedures, 

guidelines, rules, and/or regulations in doing so. DC’s conduct and/or actions constitute a breach 

of Plaintiff’s employment contract. As a result of DC’s breach, Plaintiff was denied rights, 

benefits, and/or remedies contractually afforded to Plaintiff by her contract, as well as by DC’s 

policies, procedures, guidelines, rules, and/or regulations. As a result of DC’s conduct, Plaintiff 

has been injured and/or damaged, and hereby seeks to recover her damages from DC in an amount 

that is within the jurisdictional limits of this Court and to recover any and all other remedies 

afforded by Chapter 38 of the Texas Civil Practice and Remedies Code and/or under law and/or in 

equity, including but not limited to equitable relief and her attorneys’ fees and costs.

VII. DAMAGES AND REMEDIES

29. Damages or Relief Sought. By this suit, Plaintiff, Beth Nikopoulos, is seeking actual 

damages (including economic damages and non-economic compensatory damages for emotional 

pain, mental anguish, loss of enjoyment of life, damage to reputation and humiliation). The acts and 

omissions of Defendant complained of herein were committed intentionally, knowingly, and/or 

maliciously, in complete disregard of the rights and welfare of the Plaintiff (and with reckless 

indifference to rights of the aggrieved individual protected under federal and state laws). Dr. 

Joseph and Ms. Aguilar violated clearly established Constitutional rights, as set forth herein, under 

the Fifth and Fourteenth Amendments. Additionally, or alternatively, Defendant acted with the 

degree of malice necessary to award exemplary or punitive damages. Such damages should be 

awarded in this case against DC for the good of the public to make an example of DC, and to 

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punish them as allowed by law and public policy. Accordingly, in addition to any other relief, 

Plaintiff seeks the recovery of exemplary damages from DC. 

30. Attorneys’ Fees and Costs. The Plaintiff has retained the law firm of Hill Gilstrap, 

P.C. to represent her in connection with this matter, and has agreed to pay the law firm any and all 

reasonable and necessary attorneys’ fees and costs in connection with such representation. 

Plaintiff is entitled to and seeks to recover her reasonable and necessary attorneys’ fees and costs 

incurred and to be incurred in bringing this suit and in all appeals of this suit, as permitted by law, 

in equity, and/or pursuant to 42 U.S.C. §§ 1983 and 1988(b). Additionally, pursuant to 42 U.S.C. 

§ 1988(c), Plaintiff seeks to recover any and all expert fees, which she incurs and/or may incur in 

bringing this suit.

31. Interest. The Plaintiff is also entitled to and seeks to recover pre-judgment and 

post-judgment interest at the maximum rate permitted by law. 

32. Injunctive and Declaratory Relief. The Plaintiff also seeks injunctive and 

declaratory relief requiring DC to reinstate her as Director of Student Life for the Eastfield campus, 

declaring that her termination was in violation of DC policy and her constitutional rights, and 

prohibiting DC from further adverse employment action resulting from the matters made the basis 

of this complaint, or in retaliation for Plaintiff bringing this action

VIII. CONDITIONS PRECEDENT

33. All conditions precedent to the Plaintiff’s recovery on the claims alleged herein 

have been performed or have occurred.

IX. JURY DEMAND

34. Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff requests trial 

by jury.

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Prayer for Relief

ACCORDINGLY, the Plaintiff, Beth Nikopoulos, respectfully requests: 

(a) injunctive and declaratory relief requiring DC to reinstate her as Director of Student 

Life for the Eastfield campus, declaring that her termination was in violation of DC

policy and her constitutional rights, and prohibiting DC from further adverse 

employment action resulting from the matters made the basis of this complaint, or 

in retaliation for Plaintiff bringing this action;

(b) judgment against Defendant DC for actual damages (including economic damages 

and non-economic compensatory damages for emotional pain, mental anguish, loss of 

enjoyment of life, damage to reputation and humiliation, and/or at least nominal 

damages);

(c) judgment against Defendant DC for exemplary damages in the maximum amount 

that may be awarded under applicable law;

(d) judgment against Defendant for court costs and her attorneys’ fees;

(e) judgment against Defendant for pre-judgment and post-judgment interest, as 

allowed by law; and 

(f) such other and further relief, both general and special, at law or in equity, to which 

he may be justly entitled. 

DATED: August 2, 2022. Respectfully submitted,

/s/ Frank Hill 

Frank Hill SBN 09632000

fhill@hillgilstrap.com

HILL GILSTRAP, P.C.

1400 W. Abram St.

Arlington, Texas 76013

(817) 261-2222

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(817) 861-4685 FAX

ATTORNEY FOR PLAINTIFF

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