UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF INDIANA

FORT WAYNE DIVISION

LALETA MCCLURE, )

)

Plaintiff, )

)

v. ) CAUSE NO.

)

CHECK INTO CASH OF INDIANA, LLC, )

)

Defendant. )

COMPLAINT

Plaintiff alleges against Defendant that:

1. The Plaintiff is LaLeta McClure, a resident of Allen County, New Haven Indiana at all 

material times to this Complaint.

2. The Defendant is Check Into Cash of Indiana, LLC, a company doing business at 208 East 

Pettit Avenue, #52, Fort Wayne, Indiana 46806. At all material times to this Complaint, 

the Defendant was an “employer” for the purposes of 42 U.S.C. § 1981.

3. Plaintiff filed a Charge of Discrimination on October 8, 2012, EEOC No. 24D-2013-

00030/EO-0011-A13, a copy of which is attached hereto, incorporated herein, and made a 

part hereof as Exhibit “A”.

4. Plaintiff is an African American/black individual who was employed by the Defendant 

from on or about August 10, 2012 until on or about September 21, 2012 – the date of her 

wrongful termination. Plaintiff performed within the reasonable expectations of the 

employer throughout her employment, and was a customer service representative at the 

time of her separation from employment. During Plaintiff’s employment, she had no 

perfect attendance, she maintained a professional demeanor, and had performed 

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appropriately at all times.

5. During Plaintiff’s employment, she was treated less favorably than similarly-situated 

non-African American/non-black employees as to the terms, conditions, and benefits of 

employment with the Defendant. For example, non-African American/non-black 

employees were given a mileage allowance when required to take trips to the Wells Fargo 

Bank, whereas Plaintiff was never given mileage reimbursement of any sort. In addition, 

after Plaintiff was hired in on a part-time basis, she was given full-time work hours, but not 

the benefits normally given to similarly-situated non-African American/non-black 

employees who worked full time. In addition, Plaintiff was denied a full-time position at 

Defendant’s New Haven Indiana location in spite of her qualifications for the position, 

whereas a similarly-situated Caucasian employee was hired/transferred-in to the position.

6. During Plaintiff’s employment, she was subjected to repeated verbal profanity on the 

worksite by her assistant manager which Plaintiff found extremely objectionable and 

disruptive. In response, Plaintiff submitted a complaint to the company. However, 

instead of properly investigating the complaint, as the company did when similarlysituated non-African American/non-black employees filed complaints, they were not 

thoroughly investigated and addressed. 

7. On or about September 20, 2012, Plaintiff informed her supervisor/manager that she felt 

that she was being treated more harshly and discriminated against because of her 

race/color. 

8. The following day, September 21, 2012, Plaintiff was terminated. Plaintiff alleges that 

the proffered reason for termination was false and pretextual, and that in reality, she was 

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discriminated against, retaliated against for protesting discriminatory treatment, and 

terminated on the basis of her race/color.

9. Defendant’s discriminatory and retaliatory conduct was the direct and proximate cause of 

Plaintiff suffering the loss of her job and job-related benefits including income, and also

subjected Plaintiff to inconvenience, emotional distress, and other damages and injuries.

10. Furthermore, Defendant’s discriminatory and retaliatory conduct was intentional, 

knowing, willful, wanton, and in reckless disregard of Plaintiff’s federally protected rights 

under 42 U.S.C. § 1981. Therefore, punitive damages are appropriate.

WHEREFORE, Plaintiff prays for judgment against the Defendant for compensatory 

damages, punitive damages, attorney’s fees and costs, and for all other just and proper relief in the 

premises.

JURY DEMAND

Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Plaintiff demands a trial by 

jury in this action.

Respectfully submitted,

CHRISTOPHER C. MYERS & ASSOCIATES

s/Christopher C. Myers 

Christopher C. Myers, #10043-02

809 South Calhoun Street, Suite 400

Fort Wayne, IN 46802

Telephone: (260) 424-0600

Facsimile: (260) 424-0712

E-mail: cmyers@myers-law.com

Attorneys for Plaintiff

IMS/js

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