UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

KEIONA ELLIOTT, ) 

 ) No. 20 cv 2706 

 Plaintiff, ) 

v. ) 

 ) JURY DEMANDED 

 ) 

BOARD OF EDUCATION OF THE ) 

CITY OF CHICAGO, ) 

 ) 

 Defendant. ) 

 

COMPLAINT 

 Plaintiff, KEIONA ELLIOTT, by counsel, Moor Law Office, P.C., complaining of the 

BOARD OF EDUCATION OF THE CITY OF CHICAGO, states as follows for her Complaint at 

Law: 

1. This is an action for employment discrimination brought to secure relief, legal and 

equitable, for discrimination based on sex, brought pursuant to Title VII of the Civil Rights Act of 

1964, as amended, 42 U.C.S. § 2000e et seq. (“Title VII”), and for relief under state law. The 

jurisdiction of this Court is invoked to secure protection of, and to redress deprivation of, rights 

guaranteed by law, which rights provide for injunctive and compensatory relief for illegal 

discrimination in employment. 

Jurisdiction and Venue 

1. Jurisdiction over this case is conferred on the Court by 42 U.S.C. §§ 1331, 1343, 

and 28 U.S.C. § 1367(a). 

2. Venue is proper in this District pursuant to 28 U.S.C. § 1391(b) because Plaintiff 

resides in the District and the unlawful employment practices alleged herein were committed in 

the District. 

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3. On May 1, 2017, pursuant to Defendant’s policy on sexual harassment, the 

Plaintiff filed a complaint of sexual harassment with the Chicago Public School Equal 

Opportunity Compliance Office (“EOCO”), which investigated. The EOCO found that sexual 

harassment had occurred but took no action because the harasser had allegedly retired. 

4. On or about September 20, 2017, Plaintiff filed a charge of discrimination with the 

Equal Employment Opportunity Commission (“EEOC”), charge number 440-2017-05569, 

alleging sexual harassment. The Charge sought compensatory and injunctive relief. (Ex. A, EEOC 

Charge). 

5. On February 10, 2020, U.S. Department of Justice, Civil Decision, closed its 

investigation and issued Plaintiff a right to sue letter and notice. (Ex. B, Right to Sue letter). 

6. Plaintiff filed this civil suit within 90 days of her receipt of the notice of her right 

to sue, having filed this action on May 4, 2020. 

Parties

7. Plaintiff Keiona Elliott (“Plaintiff”) currently resides, and at all relevant times 

alleged herein resided, in the City of Chicago. Plaintiff is an African-American female. Plaintiff 

at all relevant times was an “employee” within the meaning of Title VII, 42 U.S.C. § 2000(e)(f), 

having been employed by Defendant between April 2014 and the present. 

8. The Board of Education of the City of Chicago is and was at all relevant times 

a municipal corporation organized and existing under the laws of the State of Illinois, which 

maintained, managed, and/or operated the City of Chicago’s public schools. It is an “employer” 

within the meaning of Title VII of the Civil Rights Act, 42 U.S.C. § 2000e(b) because at all relevant 

times it engaged in activities affecting commerce and employed thousands of persons. 

General Allegations

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 9. Plaintiff was hired by the Board of Education to work part time on April 2014 as a 

security guard, and became full time in March 2015. She was assigned to the Al Raby High School 

in Chicago. 

 10. Her supervisor was Joseph Barr, a security employee who was also the football 

coach at Al Raby. 

 11. Barr and Chicago Public Schools Dean of Students at Al Raby, D’Angelo Dereef, 

both described Barr as Plaintiff’s supervisor to Plaintiff and others. 

 12. Beginning immediately Joseph Barr, while training Plaintiff, created a hostile work 

environment that continued through March 17, 2017. 

13. Once or twice a week he would state that he wanted to put her breasts on his mouth, 

would compliment Plaintiff’s “titties,” and he would reach out towards Plaintiff and pretend to 

touch her breasts. 

14. Plaintiff complained to a co-Dean of Students and a week later the Principal, Femi 

Skanes, held a meeting with the security staff to review the Sexual Harassment policy. Barr 

stopped making inappropriate comments until the beginning of the next school year. 

15. However, commencing with the 2015-2016 school year, Barr resumed sexually 

harassing again. Several times a week Barr would make comments about Plaintiff’s breasts, would 

purposefully stare at them, would pretend to reach for them. Barr would tell Plaintiff that he could 

follow her home and that no one would need to know that they had been together. Plaintiff asked 

Barr to stop, and reported his conduct to Dean of Students D’Angelo Dereef. Dereef would talk 

to Barr, and told Plaintiff that he had talked to Barr. Barr would stop harassing the Plaintiff for a 

matter of days after Dereef’s intervention, but would then resume. 

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16. Barr’s conduct continued, with the knowledge of Dereef, until March 17, 2017 

when Barr approached Plaintiff and said “what I was about to say. . .” While Plaintiff waited for 

Barr to complete his sentence he stared at her breasts, and then pointed at them. As Plaintiff turned 

to leave, he grabbed one of her breasts. Plaintiff started for Dereef’s office and Barr begged her 

to not report him. When Plaintiff informed Dereef what had happened Dereef told Barr that he 

knew that Bar “did not do that.” Plaintiff then reported the matter to Principal Skanes.

 17. Plaintiff, at all relevant times, performed her job as a security guard in a manner 

that met or exceeded the expectations of the Board of Education. 

COUNT I – Sexual Harassment 

 18. Plaintiff adopts paragraphs 1 – 17 above as paragraphs 1 – 17 of Count I, as if fully 

set forth herein. 

 19. The Defendant created a hostile work environment between 2014 and March 2017 

in which the Plaintiff was repeatedly and regularly subjected to unwelcome and outrageous sexual 

harassment by a supervisor. Alternatively, the Defendant created a hostile work environment 

between 2014 and March 2017 by allowing a co-worker to continue to sexually harass the Plaintiff 

even after it had been fully informed of the harassment. 

 20. As a proximate result of Defendant’s illegal conduct, Plaintiff has suffered anxiety, 

emotional distress, physical illness, damage to her reputation, loss of income, and loss of 

enjoyment of the ordinary pleasures of life. 

 WHEREFORE, Plaintiff, KEIONA ELLIOTT, by counsel, respectfully prays that this 

Court provide the following equitable and legal remedies: 

a. Enter a permanent injunction against Defendant prohibiting it from further acts of 

sexual harassment; 

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b. Award compensatory damages; 

c. Award punitive damages; 

d. Award Plaintiff the costs of litigation, including reasonable attorney’s fees and 

expert fees and expenses; and 

e. Any other relief that this Court deems just. 

Plaintiff demands trial by jury. 

COUNT II – Intentional Infliction of Emotion Distress 

 21. Plaintiff adopts paragraphs 1 – 20 above as paragraphs 1 – 20 of Count II, as if fully 

set forth herein. 

 22. As a result of the extreme and intentional conduct alleged above, which was a clear 

violation of the Board of Education’s policy on sexual harassment and of the existing law, the 

Plaintiff suffered severe emotion distress. 

 55. As a proximate result of Defendant’s illegal conduct, Plaintiff has suffered anxiety, 

emotional distress, physical illness, damage to her reputation, loss of income, and loss of 

enjoyment of the ordinary pleasures of life. 

 WHEREFORE, Plaintiff, KEIONA ELLIOTT, by counsel, respectfully prays that this 

Court enter Judgment against the BOARD OF EDUCATION OF THE CITY OF CHICAGO for 

compensatory damages and the costs of this suit. 

Plaintiff demands trial by jury. 

 /s/ Edward R. Moor 

 Attorney for Plaintiff 

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MOOR LAW OFFICE, P.C. 

One N. LaSalle Street, Suite 600 

Chicago, Illinois 60602 

312-726-6207 

erm@moorlaw.net

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