IN THE UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF OHIO

WESTERN DIVISION (CINCINNATI)

LARHONDA J. STROZIER

12130 Sycamore Terrace Drive, Apt. E

Cincinnati, Ohio 45249,

Plaintiff,

v.

WARREN COUNTY SHERIFF’S OFFICE

822 Memorial Drive

Lebanon, Ohio 45036,

Defendant.

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Case No. 17-cv-00817

Judge

COMPLAINT

WITH JURY DEMAND

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I. PARTIES

1. Plaintiff LaRhonda J. Strozier (“Plaintiff”) is an Ohio citizen who resides in 

Cincinnati, Ohio. Plaintiff is female and during all relevant times she was an employee within 

the meaning of 42 U.S.C. § 2000e(f) and Ohio Rev. Code § 4112.01(A)(3).

2. Defendant Warren County Sheriff’s Office (“Defendant”) is a law enforcement 

agency for Warren County, Ohio with its principle place of business located at 822 Memorial 

Drive, Lebanon, Ohio 45036. Defendant, among other things, operates a prison facility and 

employed Plaintiff at that facility as a corrections officer. During all relevant times, Defendant 

was an employer within the meaning of 42 U.S.C. § 2000e(b) and Ohio Rev. Code § 

4112.01(A)(2).

3. Plaintiff seeks injunctive relief, compensatory damages, punitive damages, and 

her attorney’s fees and costs associated with this action based on Defendant’s violations of Title 

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VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e, et seq., and Ohio Revised Code § 4112, 

et seq., that occurred during the course of Plaintiff’s employment with Defendant.

II. JURISDICTION AND VENUE

4. Jurisdiction in this case is proper under 42 U.S.C. § 2000e-5(f) and 28 U.S.C. § 

1343(3) and (4), which grants the District Court jurisdiction to hear this action without regard to 

the amount in controversy.

5. Venue is appropriate in this District Court under 28 U.S.C. § 1391(b) because (i) 

a substantial part of the events giving rise to Plaintiff's claims occurred in this District, and (ii) 

this is the District in which Plaintiff and Defendant reside.

6. In October 2016, Plaintiff filed a charge of employment discrimination (Charge 

No. 473-2016-01167) pursuant to Title VII based on sex discrimination with the U.S. Equal 

Employment Opportunity Commission (“EEOC”). On August 10, 2017, the EEOC issued a 

determination letter finding evidence Defendant discriminated against Plaintiff and other female 

correction officers on the basis of sex. Plaintiff was subsequently issued her right to sue letter on 

November 6, 2017. True and accurate copies of the EEOC charge, EEOC determination letter, 

and Plaintiff’s right to sue letter are attached as Exhibits A through C, respectively.

III. FACTUAL BACKGROUND

7. Plaintiff works for Defendant as a corrections officer at the Warren County Jail

located in Lebanon, Ohio. The Warren County Jail houses both male and female inmates, and 

Defendant employs both male and female corrections officers at this facility.

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8. During the course of Plaintiff’s employment, Defendant required and continues to 

require Plaintiff and other female corrections officers to work a disproportionate amount of 

mandatory female only overtime hours, shifts, and assignments. 

9. Upon information and belief, Defendant does not impose such mandatory 

obligations similarly situated male corrections officers. Defendant discriminates against its 

female corrections officers by imposing additional burdens on female corrections officers in 

determining scheduling, off days, post rotations, and assignments.

10. Despite Plaintiff and other female corrections officers raising the foregoing

discriminatory conduct with supervisors and administrative staff, Defendant refuses to 

implement employment practices that would stop Defendant’s unlawful conduct from 

continuing. For example, such non-discriminatory employment practices could include allowing

male officers to perform common officer duties or hiring additional female officers to eliminate 

the discriminatory conduct, which would eliminate the need for mandatory female only overtime 

hours.

11. Plaintiff is a single mother and the sole provider for her family. The experience 

of discrimination has caused extreme mental anguish for her and her family. As a result of 

Defendant’s discriminatory conduct, Plaintiff has been damages by (among other things) 

increased child care costs, time spent away from her family, and having to work in a 

environment hostile toward her sex.

12. As a direct and proximate result of Defendant’s conduct, Plaintiff has suffered 

and will continue to emotional distress, mental suffering and other compensatory damages.

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COUNT I

RACIAL DISCRIMINATION 

(Violation of 42 U.S.C. § 2000e-2)

13. Plaintiff incorporates by reference the allegations of paragraphs 1 through 12 of 

the Complaint as if fully set forth. 

14. Title VII expressly prohibits certain unlawful employment practices and provides, 

in part, that:

“It shall be an unlawful employment practice for an employer—

(1) to fail or refuse to hire or to discharge any individual, or otherwise to 

discriminate against any individual with respect to his compensation, terms, 

conditions, or privileges of employment, because of such individual’s race, color, 

religion, sex, or national origin; or

(2) to limit, segregate, or classify his employees or applicants for employment in 

any way which would deprive or tend to deprive any individual of employment 

opportunities or otherwise adversely affect his status as an employee, because of 

such individual’s race, color, religion, sex, or national origin.” 42 U.S.C. § 

2000e-2(a).

15. Defendant discriminated against Plaintiff on the basis of sex by forcing her to 

work mandatory overtime which male corrections offices were not required to work. Defendant 

denied Plaintiff (i) the same rights enjoyed by similarly situated male corrections officers 

employed with Defendant, and (ii) the enjoyment of all benefits, privileges, terms and conditions 

of that relationship, in violation of 42 U.S.C. § 2000e-2. 

16. Defendant conducted itself intentionally, deliberately, willfully, and in callous 

disregard of Plaintiff’s rights. 

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17. By reason of the continuous nature of Defendant’s discriminatory conduct, 

unstayed throughout the entire liability period, Plaintiff is entitled to application of the 

continuing violation doctrine to all of the violations alleged herein. 

18. By reason of Defendant’s discrimination and violations of 42 U.S.C. § 2000e-2, 

Plaintiff is entitled to all legal and equitable remedies available under 42 U.S.C. § 2000e-5, 

including injunctive relief, compensatory damages, punitive damages, and attorney’s fees and 

costs.

COUNT II

UNLAWFUL DISCRIMINATORY PRACTICES

(Violation of Ohio Rev. Code § 4112 et seq.)

19. Plaintiff incorporates by reference the allegations of paragraphs 1 through 18 of 

the Complaint as if fully set forth. 

20. The Ohio Unlawful Discrimination Practices Statute (Ohio Rev. Code § 4112 et

seq.) prohibits certain unlawful discriminatory practices by employers towards their employees.

21. Defendant violated Chapter 4112 by discriminating against Plaintiff on the basis 

of her sex.

22. By reason of Defendant’s discrimination and violations of Chapter 4112, Plaintiff 

is entitled to all legal and equitable remedies available under Ohio Rev. Code § 4112.99, 

including injunctive relief, compensatory damages, punitive damages, and attorney’s fees and 

costs.

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PRAYER FOR RELIEF

WHEREFORE, Plaintiff asks this Court to enter judgment in her favor as

follows on each claim for relief:

A. Award Plaintiff equitable relief enjoining Defendant’s unlawful conduct;

B. Award Plaintiff nominal and compensatory damages in an amount to be 

determined at trial;

C. Award Plaintiff punitive damages from Defendant’s willful and malicious 

conduct in an amount to be determined at trial;

D. Award Plaintiff pre-judgment and post-judgment interest in an amount to be 

determined at trial;

E. Award Plaintiff her attorney’s fees, costs and expenses in an amount to be 

determined at trial; and

F. Award Plaintiff such other and further relief as this Court deems necessary.

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Respectfully submitted,

/s/ Adam V. Sadlowski 

Adam V. Sadlowski, Trial Attorney (0079582)

Cori R. Besse (0081447)

SADLOWSKI & BESSE L.L.C.

11427 Reed Hartman Highway, Suite 217

Blue Ash, Ohio 45241

Tel: (513) 618-6595

Fax: (513) 618-6442

asadlowski@sb-lawyers.com

cbesse@sb-lawyers.com

Attorneys for Plaintiff 

JURY DEMAND

Plaintiff demands a trial by jury on all triable issues.

/s/ Adam V. Sadlowski 

Adam V. Sadlowski

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