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UNITED STATES DISTRICT COURT FOR THE 

NORTHERN DISTRICT OF ILLINOIS

CHASSITY THOMAS, 

by and through her legal guardian, 

NINA PHILLIPS;

Plaintiff,

 

vs. Case No.:

ILLINOIS CENTER FOR 

REHABILITATION AND EDUCATION,

an Illinois not for profit corporation;

JEWISH VOCATIONAL SERVICES, 

an Illinois not for profit corporation;

JEWISH FEDERATION OF METROPOLITAN, 

an Illinois not for profit corporation; and EDWARD FORD

Defendants.

____________________________________________/

COMPLAINT

COMES NOW, Plaintiff, CHASSITY THOMAS, by and through her legal guardian, 

NINA PHILLIPS, (“THOMAS”), individually, and hereby files this Complaint by and through the 

undersigned counsel against the above-named Defendants, ILLINOIS CENTER FOR 

REHABILITATION AND EDUCATION, (“REHAB CENTER”); JEWISH VOCATIONAL 

SERVICES, (“JVS”); JEWISH FEDERATION OF METROPOLITAN, (“JFM”), and 

Defendant EDWARD FORD (“FORD”); for causing the sexual assault and battery of 

CHASSITY THOMAS, on June 27, 2019, for which Plaintiff now seeks damages, and in support 

thereof alleges as follows:

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VENUE, JURISDICTION, AND PARTIES

1. At all material times hereto, Plaintiff, CHASSITY THOMAS, (hereinafter 

“THOMAS”) and her legal guardian NINA PHILLIPS were and remain residents of Cook County, 

Illinois.

2. Defendant, ILLINOIS CENTER FOR REHABILITATION AND EDUCATION, 

(hereinafter “REHAB CENTER”); is an Illinois not for profit corporation, which operates as a 

residential school for students with severe physical disabilities and other health impairments, 

which at the time of incident was located at: 1151 South Wood, Chicago, Illinois 60611. Defendant 

REHAB CENTER was at all times material hereto, operating and conducting business in Chicago, 

Illinois; and as such, was responsible for the actions and omissions of its agents, employees and 

students; including establishing policies regarding the hiring, training, supervision and retention

of its employees, establishing policies regarding the supervisions of its own students, and 

establishing policies to ensure the safety of all persons inside its in premises, pursuant to Illinois 

law.

3. Defendant, JEWISH VOCATIONAL SERVICES, (hereinafter “JVS”), is an 

Illinois not for profit corporation, organized and existing under the laws of the state of Illinois, 

which operates as an employment agency located at: 216 West Jackson Blvd, Suite 700, 

Chicago, Illinois 60606, and specializes in finding employment positions for disabled persons. At 

all times material hereto, JVS was operating and conducting business in Chicago, Illinois, which 

includes but is not limited to: ensuring their employees were being placed in a safe work 

environment, and performing screenings to ensure the safety of their employees as well as the 

safety of the facilities with which it contracted.

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4. Defendant, JEWISH FEDERATION OF METROPOLITAN, (hereinafter “JFM”), 

is an Illinois not for profit corporation organized and existing under the laws of the state of Illinois. 

At all times material hereto, JFM was operating and conducting business in Chicago, Illinois, 

which includes but is not limited to being a source of financial support for JVS, and being in 

partnership with JVS. 

5. At all times material hereto, Defendant FORD, was in the care, custody and control 

of Defendant REHAB CENTER as a participant of their residential program, and was at all times 

material hereto and remains a resident of Cook County, Illinois. 

6. All of the acts or omissions giving rise to this action occurred in the City of 

Chicago, Cook County, Illinois. 

7. Venue is proper in Cook County, Illinois as the incident arises out of Cook County, 

and Defendants operate businesses and/or a governmental agency and/or reside and/or work in 

Cook County.

8. Jurisdiction is proper in this Court pursuant to: Americans with Disabilities Act, 

Title II, Civil Rights Act Title II and Title VII, This is an action seeking damages in excess of 

seventy-five thousand dollars ($75,000.00), exclusive of costs, interest, and attorney’s fees. 

FACTUAL ALLEGATIONS

8. Plaintiff, THOMAS, is a 32-year-old woman who suffers from down syndrome 

along with visual and verbal impairments. JVS is an employment agency who specializes in 

finding employment positions for disabled persons. The REHAB CENTER utilized the janitorial 

services of JVS, and THOMAS was placed on its premise as a janitorial worker. 

9. JVS was fully aware of the range and nature of THOMAS’s verbal and visual 

disability yet assigned THOMAS to work as a janitor inside the men’s locker room at the REHAB 

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CENTER. In addition, JVS assigned THOMAS as a janitor at the REHAB CENTER and failed 

to require that the REHAB CENTER properly supervise THOMAS to ensure her safety.

10. During her employment at the REHAB CENTER, a student by the name of Edward 

Ford (“Ford”), who was recently released from prison and who has visual impairments, but not 

mental impairments, was in the care and control of the REHAB CENTER. On various occasions, 

Ford made it known to other students of the REHAB CENTER, as well as other employees and 

staff members, that he had just been released from prison and “needed some,” referring to sexual 

intercourse, including supervisors. As such, REHAB CENTER supervisors and employees had 

actually knowledge that he was sexually harassing staff and/or other persons on the premises with 

his sexualized and inappropriate conversation and remarks.

11. Toni Butler (“Butler”), a REHAB CENTER dorm room counselor, was made aware 

of these comments and then reported it to the REHAB CENTER Superintendent; however, Ford 

was not removed from the REHAB CENTER to protect employees, students, and persons on its 

premises.

12. The REHAB CENTER’s physical education instructor had also been previously 

made aware that Ford would wait in the locker room for extended periods of time when THOMAS 

was scheduled to clean the men’s locker room. Despite this knowledge, the physical education 

instructor did not request that Ford leave the premises, nor did he inform a superior that Ford was 

hanging around the locker room.

13. On June 27, 2019, THOMAS had been assigned to clean the men’s locker room 

alone. Ford cornered THOMAS in the locker room, and with his fingers penetrated her vagina and 

inserted his penis into her buttocks. All the while, there were no REHAB CENTER agents and/or 

employees to intervene and stop the attack.

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14. After the incident, THOMAS desperately tried to communicate what she had just 

endured, but due to her disability it was difficult to articulate and staff members at the REHAB 

CENTER ignored her and did not make an effort to ascertain the cause of her fear and unrest. JVS 

retaliated against her for attempt to seek protection as a Black, disabled woman, attempting to 

report and act of sexual battery against her person and punished her by suspending her from work.

15. On June 28, 2019, THOMAS was able to communicate that Ford had sexually 

battered her to a REHAB CENTER employee whose last name is Butler. The Illinois State Police 

were called, and THOMAS was taken the University of Illinois Emergency room where a rape kit 

was performed.

16. As of the date of the subject incident, THOMAS’ behavior has drastically changed 

as she began to act out after and exhibited clear signs of trauma, she is unable to sleep in complete 

darkness and requires that a night light be left on. THOMAS also has constant nightmares and 

otherwise exhibits symptoms of severe psychological distress.

17. The REHAB CENTER had actual prior knowledge of Ford’s history as well as the 

comments Ford was making about “needing some,” in reference to sexual intercourse. This prior 

knowledge put staff members and the Superintendent on notice that Ford posed a danger to 

everyone inside its facility. Not only were other staff members aware, but Butler, the dorm 

counselor, personally informed the REHAB CENTER’S Superintendent of these threatening 

comments. 

18. Despite the REHAB CENTER’s actual knowledge, Ford was allowed to stay at the 

REHAB CENTER unsupervised. Staff members of the REHAB CENTER had actual knowledge 

that Ford would purposely stay in the men’s locker room longer than he needed to be to wait for 

THOMAS. 

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19. The REHAB CENTER failed to take reasonable and adequate safety and security 

measures to prevent the sexual abuse of their employees and/or staff and business invitees. Ford 

knowingly and willingly took advantage of THOMAS and her inability to escape his advances, 

and actually and proximately caused the damages and injuries suffered by THOMAS. 

20. The REHAB CENTER’s numerous actions and omissions actually and proximately 

caused THOMAS’ physical injury and severe emotional distress and affecting her day-to-day life 

and will more likely than not continue into the future and be permanent in nature. 

21. In addition, JVS had actual prior knowledge of THOMAS’ disability as well as her 

verbal and visual impairments. This prior knowledge along with the fact that JVS was in the 

practice of placing people with disabilities into several different assignments with different 

facilities, put the agents and/or staff at JVS that THOMAS’ placement would require extra 

responsibility in determining that it was adequately safe for THOMAS to work there. 

22. Despite JVS’ knowledge of the circumstances surrounding THOMAS’ disability 

and without regard to her safety, JVS placed THOMAS to work at a facility without any 

investigation into the facility’s safety record, safety policies, and/or any investigation as to the 

students that were matriculated at the REHAB CENTER. 

23. JVS did not require the REHAB CENTER to notify JVS when students or persons 

on its property and/or in their custody and/or control had criminal records or posed a threat of 

sexual and/or physical violence to others. 

24. JVS had a duty to properly screen the locations in which it placed its employees to 

ensure their safety. Specifically, JVS placed THOMAS at the REHAB CENTER as a janitor in the 

men’s locker room without any safety requirements, policies and/or procedures that would ensure 

THOMAS’ safety. 

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25. JVS failed to take reasonable and adequate safety and security measures to prevent 

the sexual abuse of their employees and/or staff. JVS failed to implement policies and/or 

procedures to keep mentally disabled employees safe and/or to prevent their exposure to sexual 

battery and physical violence during the course and scope of their employment. JVS failed to take 

reasonable safety and security measures to protect THOMAS during her employment and prevent 

an attack on her person that resulted in her sexual abuse and battery. 

26. As a direct and/or proximate result of the REHAB CENTER and JVS’ actions 

and/or inactions stated above, THOMAS suffered discomfort and continues to suffer pain of mind 

and body, shock, emotional distress, severe psychological injury, physical manifestations of 

emotional distress, embarrassment, loss of self-esteem, disgrace, fright, grief, humiliation, and loss 

of enjoyment of life, and was prevented and will continue to be prevented from performing daily 

activities and obtaining the full enjoyment of life. As aforementioned, the REHAB CENTER and 

JVS are actually and proximately liable for the injuries and damages sustained by THOMAS.

27. Plaintiff CHASSITY THOMAS, by and through her legal guardian NINA 

PHILLIPS, is entitled to damages and will seek economic, compensatory, severe psychological

injuries, pain and suffering, and punitive damages in an amount to be proven at trial, but which is 

alleged to be in excess of $75,000.00 including interest, together with costs and reasonable 

attorney’s fees incurred herein and such other relief as the Court deems just and equitable and files 

the instant action to demand an award for injuries and damages against Defendants REHAB 

CENTER, JVS, JFM, and FORD.

COUNT I

VIOLATION OF TITLE II OF THE AMERICANS WITH DISABILITIES ACT 

AGAINST JVS and JVM

28. Plaintiff incorporates paragraphs 1 through 27 as if fully stated herein.

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29. The Americans with Disabilities Act of 2008 (hereinafter “ADA”), prohibits any 

individual with a disability to be excluded from participation in or be denied the benefits of the 

services, programs or activities of a public entity or be subjected to discrimination by such entity.

Such benefits include, but are not limited to, being afforded the same protections and safety 

precautions while inside the premises of her employer.

30. Section 5.01 of the ADA also finds liability against, employers participating in a 

contractual or other arrangement that results in discrimination against a person with a disability.

Specifically, the ADA states that an employer may be liable not only for its own discrimination, 

but also for the discrimination of third parties, and that an employer commits discrimination if the 

employer participates in a contractual or other relationship that has the effect of discriminating 

against a qualified applicant or employee with a disability. The ADA holds both the employer and 

that third party responsible for discrimination that occurs to its employees regardless of whether 

the entity that perpetrates the discrimination is the employer or some other entity with which the 

employer has contractual dealings.

31. THOMAS is a black female with down syndrome, in addition to visual and verbal 

impairments, who was an employee of JVS and JVM was treated less favorably than her nondisabled and non-black colleagues. Due to the JVS and JVM’s contractual relationship with the 

REHAB CENTER, THOMAS performed janitorial services on its property, and REHAB 

CENTER, JVS, and JVM are liable for discrimination against THOMAS. JVS and JVM 

specifically assigned her and had actual knowledge that she was cleaning the men’s locker room 

by herself, that she needed heighted protection due to her disability, and they failed to take any

precautions to protect her while performing her janitorial services, did not require that the REHAB 

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CENTER close the locker room during cleanings and/or require the REHAB CENTER to have 

another person to be present in the locker room to ensure her safety.

32. As a disabled worker, and under the ADA, THOMAS was entitled to the same 

benefits and protections, if not more protection, as her peers who did not have a disability, that 

were also employed through JVS and JVM. Due to THOMAS’ disability, JVS and JVM purposely 

ignored the need to screen and/or investigate the THOMAS’ placement at the REHAB CENTER, 

and failed to take the adequate safety measures to ensure THOMAS’ safety while she performed 

her janitorial services at the REHAB CENTER. 

33. JVS and JVM decided to take no action when it came to ensure that this placement 

would not pose a danger to THOMAS’ safety. JVS knew of THOMAS’ disability, and visual and 

verbal impairments and assumed responsibility for her employment when they assigned her the 

position and took charge of her safety related to her employment. 

34. JVS and JVM could have prevented the sexual battery of THOMAS had they 

fulfilled their duty in investigating and/or screening the facilities where they place their employees. 

JVS and JVM allowed the REHAB CENTER and Ford access to THOMAS by wrongfully placing 

her into a dangerous and unsupervised environment. JVS and JVM allowed THOMAS to be 

sexually battered because they did not deem THOMAS was worth protecting like they protect their 

other non-disabled employees and/or persons they were in charge of JVS and JVM’s lack of care

in investigating the facilities in which they placed their disabled employees, lack of action in 

preventing a sexual battery against THOMAS, actually and proximately caused THOMAS’ rape. 

When THOMAS’ attempted to report the sexual battery to persons at the REHAB CENTER, 

instead of investigating what transpired and what was causing her distress, they retaliated against 

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her and punished her for trying to report that she was a victim of sexual battery and suspended her 

for two days.

35. As a direct and proximate result of JVS and JVM’s actions and omissions in 

violation of the ADA, THOMAS suffered significant damages and emotional injuries including 

mental and emotional damage and trauma, humiliation, damage to her personal reputation, mental 

distress, and anguish for which JVS and JVM are liable.

36. Plaintiff, THOMAS was subjected to sexual abuse, sexual battery, and endured 

emotional distress, severe psychological injuries, humiliation, mental anguish, which has 

manifested into episodes of acting out, restlessness, anxiety; shock and fright; embarrassment; loss 

of everyday social pleasures and enjoyment; and other injuries and disablements which have yet 

to manifest themselves at this time which have all resulted in medical bills, loss of future earning

potential, as well as other expenditures that will be incurred in the future.

37. WHEREFORE, Plaintiff CHASSITY THOMAS, by and through her legal 

guardian, NINA PHILLIPS, demands judgment for damages against Defendants JVS, and JVM in 

excess of the jurisdictional limits of this court, together with interest, attorneys’ fees and costs.

COUNT II

VIOLATION OF TITLE II OF THE AMERICANS WITH DISABILITIES ACT 

AGAINST DEFENDANT REHAB CENTER

38. Plaintiff incorporates paragraphs 1 through 27 as if fully stated herein.

39. The Americans with Disabilities Act of 2008 (hereinafter “ADA”), prohibits any 

individual with a disability to be excluded from participation in or be denied the benefits of the 

services, programs or activities of a public entity or be subjected to discrimination by such entity.

Such benefits include, but are not limited to, being afforded the same protections and safety 

precautions while inside the premises of her employer.

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40. Section 5.01 of the ADA also finds liability against, employers participating in a 

contractual or other arrangement that results in discrimination against a qualified employee with a 

disability. Specifically, the ADA states that an employer may be liable not only for its own 

discrimination, but also for the discrimination of third parties, and that an employer commits 

discrimination if the employer participates in a contractual or other relationship that has the effect 

of discriminating against a qualified applicant or employee with a disability. The ADA holds both 

the employer and that third party responsible for discrimination that occurs to its employees 

regardless of whether the entity that perpetrates the discrimination is the employer or some other 

entity with which the employer has contractual dealings.

41. THOMAS is a black female with down syndrome, in addition to visual and verbal 

impairments, who was an employee of JVS and JVM and was treated less favorably than her nondisabled and non-black colleagues. Due to the JVS and JVM’s contractual relationship with the 

REHAB CENTER, THOMAS performed janitorial services on its property, and REHAB 

CENTER, JVS, and JVM are liable for discrimination against THOMAS. JVS and JVM 

specifically assigned her and had actual knowledge that she was cleaning the men’s locker room 

by herself, that she needed heighted protection due to her disability, and they failed to take any

precautions to protect her while performing her janitorial services, did not require that the REHAB 

CENTER close the locker room during cleanings and/or require the REHAB CENTER to have 

another person to be present in the locker room to ensure her safety.

42. As a disabled worker, and under the ADA, THOMAS was entitled to the same 

benefits and protections, if not more protection, as her peers who did not have a disability, that 

whose employment services were utilized by Defendant REHAB CENTER. Due to THOMAS’

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disability, the REHAB CENTER, and failed to take the adequate safety measures to ensure 

THOMAS’ safety while she performed her janitorial services at the REHAB CENTER. 

43. JVS decided to take no action when it came to ensure that this placement would not 

pose a danger to THOMAS’ safety. JVS knew of THOMAS’ disability and verbal impairments 

and assumed responsibility for her employment when they assigned her the position and took 

charge of her safety related to her employment. 

44. REHAB CENTER could have prevented the sexual battery of THOMAS had it 

properly supervised its residential students including FORD, who was recently released from 

prison and posed a known imminent danger of sexual violence to persons on the property. REHAB

CENTER also failed to establish proper policy and protocol for persons with disabilities 

performing janitorial services on its property, including ensuring that disabled female janitors were 

not left alone to clean the men’s locker room. REHAB CENTER gave Ford access to THOMAS 

by allowing her to clean the men’s locker room alone and without supervision, and by allowing 

him to remain for extended periods of time unsupervised in the locker room. REHAB CENTER

allowed THOMAS to be sexually battered because they did not deem THOMAS was worth 

protecting like they protect their other non-disabled employees and/or persons performing services 

on their property, their actions and inactions actually and proximately caused THOMAS’ rape. 

45. As a direct and proximate result of REHAB CENTER’s actions and omissions in 

violation of the ADA, THOMAS suffered significant damages and emotional injuries including 

mental and emotional damage and trauma, humiliation, damage to her personal reputation, mental 

distress, and anguish for which JVS is liable.

46. Plaintiff, THOMAS was subjected to sexual abuse, sexual battery, and endured 

emotional distress, severe psychological injuries, humiliation, mental anguish, which has 

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manifested into episodes of acting out, restlessness, anxiety; shock and fright; embarrassment; loss 

of everyday social pleasures and enjoyment; and other injuries and disablements which have yet 

to manifest themselves at this time which have all resulted in medical bills, loss of future earning

potential, as well as other expenditures that will be incurred in the future.

47. WHEREFORE, Plaintiff CHASSITY THOMAS, by and through her legal 

guardian, NINA PHILLIPS, demands judgment for damages against Defendants, REHAB 

CENTER in excess of the jurisdictional limits of this court, together with interest, attorneys’ fees 

and costs.

COUNT III

VIOLATION OF TITLE VII OF THE CIVIL RIGHTS ACT AGAINST JVS and JVM 

BASED ON RACE, SEX, and RETALIATION

48. Plaintiff incorporates paragraphs 1 through 27 as if fully stated herein.

49. Title VII of the Civil Rights Act prohibits employer from discriminating based on 

race and sex against employees. At all times material hereto, Defendant JVS and JVM employed 

African American female Plaintiff THOMAS, and discriminated against her based on her sex and 

race, and treated her differently from their non-Black non-female employees. 

50. THOMAS is a black female with down syndrome, in addition to visual and verbal 

impairments, who was an employee of JVS and JVM was treated less favorably than her non-black 

colleagues and non-female colleagues. THOMAS was consistently assigned less favorable job 

duties, including she was assigned to clean the men’s locker room at Defendant REHAB CENTER 

by herself, and with no supervision. JVS and JVM failed to place any protective measures in place 

to protect her person, including but not limited to:

(a) failed to implement safety precautions for THOMAS;

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(b) failed to properly train its employees and/or agents in procedures that would assure 

the safety of its disabled employees while assigned at other facilities and prevent 

sexual misconduct;

(c) failed to implement policies and/or procedures that would prevent such misconduct;

(d) failed to implement policies and/or procedures to ensure that the REHAB CENTER

had a policy to require the locker room to be vacant while it was being cleaned;

(e) failed to provide THOMAS with signs to close the restroom, or objects to place in 

the doorway to obstruct entrance to the bathroom during cleaning, since they were 

aware that THOMAS, a disabled woman was assigned to clean it;

(f) failed to establish a policy that required the supervision of its own employees, 

especially the mentally disabled persons that were assigned to clean the locker room 

of the opposite sex;

(g) failed to promulgate adequate policies and procedures to protect its female and/or 

African American employees;

(h) failed to require the REHAB CENTER to report any person on its premises with a 

known criminal history and/or any known sexual misconduct to JVS for the safety 

of its employees;

(i) failed to require more than one employee clean the restroom together for safety, 

knowing that generally the employees who worked as janitors inside the facility are 

disabled, Black, and female; and,

(j) such other failures as may be revealed through discovery.

51. JVS and JVM decided to take no action when it came to ensure that this placement 

would not pose a danger to THOMAS’ safety as Black female disabled employee. JVS and JVM 

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could have prevented the sexual battery of THOMAS had they fulfilled their duty in investigating 

and/or screening the facilities where they place their employees. JVS and JVM allowed the 

REHAB CENTER and Ford access to THOMAS by wrongfully placing her into a dangerous and 

unsupervised environment. JVS and JVM allowed THOMAS to be sexually battered because they 

did not deem THOMAS was worth protecting like they protect their other non-Black and nonFemale employees, and JVS and JVM’s lack of action in preventing a sexual battery against 

THOMAS, actually and proximately caused THOMAS’ rape. When THOMAS attempted to 

report the sexual battery to persons at the REHAB CENTER, instead of investigating what 

transpired and what was causing her distress, they retaliated against her and punished her for trying 

to report that she was a victim of sexual battery and that a violent crime was committed against 

her person based on her race and sex, Defendants JVS and JVM suspended her for two days.

52. As a direct and proximate result of JVS and JVM’s actions and omissions in 

violation of Title VII of the Civil Rights Act, THOMAS suffered significant damages and 

emotional injuries including mental and emotional damage and trauma, humiliation, damage to 

her personal reputation, mental distress, and anguish for which JVS and JVM are liable.

53. Plaintiff, THOMAS was subjected to sexual abuse, sexual battery, and endured 

emotional distress, severe psychological injuries, humiliation, mental anguish, which has 

manifested into episodes of acting out, restlessness, anxiety; shock and fright; embarrassment; loss 

of everyday social pleasures and enjoyment; and other injuries and disablements which have yet 

to manifest themselves at this time which have all resulted in medical bills, loss of future earning 

potential, as well as other expenditures that will be incurred in the future.

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54. WHEREFORE, Plaintiff CHASSITY THOMAS, by and through her legal 

guardian, NINA PHILLIPS, demands judgment for damages against Defendants JVS, and JVM in 

excess of the jurisdictional limits of this court, together with interest, attorneys’ fees and costs.

COUNT IV

VIOLATION OF TITLE II OF THE CIVIL RIGHTS ACT AGAINST REHAB CENTER 

BASED ON DISCRIMINATION IN A PUBLIC ACCOMODATION BASED ON RACE 

55. Plaintiff incorporates paragraphs 1 through 27 as if fully stated herein.

56. Title II of the Civil Rights Act prohibits REHAB CENTER from discriminating 

against persons based on race in a public accommodation. At all times material hereto, Defendant 

REHAB CENTER discriminated against African American female Plaintiff THOMAS, based on 

her race, and treated her differently from their non-Black non-female persons utilizing its public 

accommodation. 

57. THOMAS was consistently assigned less favorable job duties on REHAB 

CENTER’s premises, including she was assigned to clean the men’s locker room at Defendant 

REHAB CENTER by herself, and with no supervision. Defendant REHAB CENTER failed to 

place any protective measures in place to protect her person, including but not limited to:

(a) failed to implement safety precautions for THOMAS;

(b) failed to properly train its employees and/or agents in procedures that would assure 

the safety of its Black female disabled employees while assigned at other facilities 

and prevent sexual misconduct;

(c) failed to implement policies and/or procedures that would prevent such misconduct;

(d) failed to implement policies and/or procedures to ensure that the REHAB CENTER

had a policy to require the locker room to be vacant while it was being cleaned;

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(e) failed to provide THOMAS with signs to close the restroom, or objects to place in 

the doorway to obstruct entrance to the bathroom during cleaning, since they were 

aware that THOMAS, a disabled woman was assigned to clean it;

(f) failed to establish a policy that required the supervision of its own employees, 

especially the mentally disabled persons that were assigned to clean the locker room 

of the opposite sex;

(g) failed to promulgate adequate policies and procedures to protect African American 

persons on its property;

(h) failed to report any person on its premise with a known criminal history and/or any 

known sexual misconduct to REHAB CENTER for the safety of persons present in 

its accommodations;

(i) failed to require more than one employee clean the restroom together for safety, 

knowing that generally the employees who worked as janitors inside the facility are 

disabled, Black, and female; and,

(j) such other failures as may be revealed through discovery.

58. REHAB CENTER decided to take no action when it came to ensure that this 

placement would not pose a danger to THOMAS’ safety as Black female disabled person on its 

property. REHAB CENTER could have prevented the sexual battery of THOMAS had they 

removed FORD from their property, adequately supervised him, prevented him from loitering in 

the men’s locker room without supervision, and if it had prevented Ford access to THOMAS by 

wrongfully placing her into a dangerous and unsupervised environment. REHAB CENTER 

allowed THOMAS to be sexually battered because they did not deem THOMAS was worth 

protecting like they protect non-Black persons on their property, and REHAB CENTER’S lack of 

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action in preventing a sexual battery against THOMAS, actually and proximately caused 

THOMAS’ rape. 

59. As a direct and proximate result of REHAB CENTER’s actions and omissions in 

violation of Title II of the Civil Rights Act, THOMAS suffered significant damages and emotional 

injuries including mental and emotional damage and trauma, humiliation, damage to her personal 

reputation, mental distress, and anguish for which REHAB CENTER is liable.

60. Plaintiff, THOMAS was subjected to sexual abuse, sexual battery, and endured 

emotional distress, severe psychological injuries, humiliation, mental anguish, which has 

manifested into episodes of acting out, restlessness, anxiety; shock and fright; embarrassment; loss 

of everyday social pleasures and enjoyment; and other injuries and disablements which have yet 

to manifest themselves at this time which have all resulted in medical bills, loss of future earning 

potential, as well as other expenditures that will be incurred in the future.

61. WHEREFORE, Plaintiff CHASSITY THOMAS, by and through her legal 

guardian, NINA PHILLIPS, demands judgment for damages against Defendant REHAB CENTER 

in excess of the jurisdictional limits of this court, together with interest, attorneys’ fees and costs.

COUNT V

PREMISES LIABILITY AGAINST DEFENDANT, REHAB CENTER

62. Plaintiff incorporates paragraphs 1 through 27 as if fully stated herein.

63. The REHAB CENTER owed a duty to THOMAS to take precautions to protect her 

from foreseeable harm based on premise liability based upon Illinois Statute 740 ILCS 130/1 & 2.

64. At all times material hereto, Defendant REHAB CENTER was in control, 

possession and/or was the owner of the premises located at: 1151 South Wood, Chicago, Illinois 

60611, and owed the duty of reasonable care under the existing circumstances of the property to 

keep and maintain the premises in a reasonably safe condition for all persons on its premises.

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65. At all times relevant hereto, Defendant, REHAB CENTER knew that Ford, a 

student within its care and control, was creating an unsafe environment for all persons inside its 

premises. Specifically, REHAB CENTER has actual knowledge that Ford was recently released 

from prison, making statements of his desire to engage in sexual activity and otherwise sexually 

harassing others at the facility with inappropriate sexual conversation that was known to 

supervisors, and REHAB CENTER also had actual knowledge that Ford was waiting around in 

the men’s locker room on the days that THOMAS was scheduled to work. The fact that Ford has 

a prior criminal background, was recently released from prison, and had engaged in sexual 

harassment of persons on the premise and posed an imminent threat of sexual misconduct and 

violence, was not open and obvious and could not have been known to THOMAS; therefore, 

Defendant REHAB CENTER had a duty to warn persons on the premise including Plaintiff 

THOMAS and her employer Defendant JVS for her protection, and to otherwise take reasonable 

steps to protect Plaintiff THOMAS.

66. Despite prior knowledge and notice, the REHAB CENTER breached said duty 

when they negligently assigned and/or allowed THOMAS to clean the men’s locker room without 

supervision and on June 27, 2019, Ford cornered THOMAS in the locker room, and with his 

fingers penetrated her vagina and inserted his penis into her buttocks. The REHAB CENTER had 

actual knowledge of Ford’s past conduct and coupled with his comments, and it either knew or 

should have known that the danger Ford posed was imminent. Therefore, the injury to THOMAS

was both foreseeable and preventable. But for the REHAB CENTER’s negligent acts and negligent 

failures to act, THOMAS would not have been subjected to the sexual abuse, harassment, assault, 

and battery, by Ford.

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67. Plaintiff’s injuries were the direct and proximate result of the carelessness and 

negligence of Defendant REHAB CENTER, its agents, servants, employees, and workers as 

follows:

(a) failing to properly supervise Ford;

(b) failing to protect THOMAS from sexual abuse by Ford, a student under its control 

and supervision.

(c) failing to develop and implement proper policies and procedures that would prevent 

sexual misconduct, and specifically failed to protect THOMAS from 

sexual abuse by Ford, a student under its control and supervision.

(d) failing to properly train its employees and/or agents in procedures that would 

prevent sexual misconduct;

(e) failing to implement policies and/or procedures that would prevent such 

misconduct and protect its fellow students and employees;

(f) failing to place signage closing the locker room during cleaning, or otherwise 

prevent or notify students and persons on the premise that it was closed for 

cleaning;

(g) failed to create and enforce procedures and policies to prevent and/or deter sexual 

misconduct by students of the REHAB CENTER, specifically sexual misconduct 

directed towards THOMAS, a disabled person while on the premises of REHAB 

CENTER;

(h) failing to implement policies that would assure the locker room be vacant while it 

was being cleaned, since they were aware that THOMAS, a disabled black woman 

was assigned to clean it; 

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(i) failing to establish a policy that required supervision of the persons that were 

assigned to clean the locker room of the opposite sex, knowing that generally the 

employees who worked as janitors inside the facility, were disabled; and

(j) such other negligence as may be revealed through discovery.

68. The sexual abuse, sexual assault, and sexual battery and the resulting injuries and 

damages suffered by THOMAS, were reasonably foreseeable due to REHAB CENTER’s own 

failures in ensuring compliance with the law. The REHAB CENTER failed to take proper action 

to protect THOMAS from the foreseeable harm that she would be sexually abused, assaulted, and 

battered, inside its premises.

69. As a direct and proximate cause of the REHAB CENTER’s breach of its numerous

duties owed to THOMAS, she sustained ongoing and permanent injuries and damages. THOMAS

was subjected to sexual abuse, sexual battery, and endured emotional distress, severe 

psychological injuries, humiliation, mental anguish, which has manifested into episodes of acting 

out, restlessness, anxiety; shock and fright; embarrassment; loss of everyday social pleasures and 

enjoyment; and other injuries and disablements which have yet to manifest themselves at this time 

which have all resulted in medical bills, loss of future earning potential, as well as other 

expenditures that will be incurred in the future.

70. WHEREFORE, Plaintiff CHASSITY THOMAS, by and through her legal 

guardian, NINA PHILLIPS, demands judgment for damages against Defendant REHAB CENTER

in excess of the jurisdictional limits of this court, together with interest, attorneys’ fees and costs.

COUNT VII

NEGLIGENT HIRING, TRAINING, SUPERVISION AND RETENTION

OF DEFENDANT, REHAB CENTER’S AGENTS AND/OR EMPLOYEES

71. Plaintiff incorporates paragraphs 1 through 27 as if fully stated herein.

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72. The REHAB CENTER owed a duty to Plaintiff, THOMAS, to act in a reasonably 

safe manner and to properly hire, train, and supervise its employees and/or agentsfor the protection 

of all persons inside its premises, and to prevent its employees and/or agents from injuring persons 

inside its premises through intentional acts, negligence, carelessness, or otherwise. Additionally, 

the REHAB CENTER owed a duty to those on its premise not to engage in negligent hiring of its 

employees; and breached said duty by failing to hire competent staff, failing to conduct appropriate 

background checks and/or otherwise properly investigate into the background of its staff.

73. The sexual battery of THOMAS by Ford, a REHAB CENTER student, in the care, 

custody, control and supervision of the REHAB CENTER’s employees was caused by the REHAB 

CENTER’s failure to properly hire, train, supervise, and retain its employees and/or agents who 

worked alongside THOMAS. 

74. The REHAB CENTER is in the practice of working and rehabilitating physically and 

mentally disabled students, therefore, the REHAB CENTER should have known that untrained 

and incompetent staff would create a danger to its students. 

75. The REHAB CENTER’s failure to properly examine the qualifications of its 

potential staff members prior to hiring, led to the hiring of incompetent and unqualified staff which 

caused the injuries to THOMAS.

76. The REHAB CENTER also owed a duty to properly train its employees, and 

breached that duty when it failed to properly train its staff on proper procedures and policies to 

protect the interest of the persons present on its premise, especially the persons with visual and 

verbal impairments, to keep them safe from harm including sexual violence, and failed to train 

staff on how to supervise the students.

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77. The REHAB CENTER’s lack of training is evidenced in the fact that there were

multiple staff members whom were aware of the comments that Ford had made before his attack 

on THOMAS, yet, no staff members acted in a way that would have prevented such an attack. The 

REHAB CENTER failed to train its employees and/or staff members on how to approach 

situations and students with criminal backgrounds and manifesting signs of a sexual predator like

Ford. 

78. The REHAB CENTER also failed to properly train its staff on protocol and 

procedure for closing bathrooms during cleanings and/or ensuring that there was more than one 

person cleaning the locker room at a time, and/or ensuring that women were protected while 

cleaning the men’s locker room. The REHAB CENTER’s failure to properly train its staff resulted 

in the failure to act on behalf of the REHAB CENTER, which led to THOMAS’ sexual battery or 

rape inside of the REHAB CENTER’s men’s locker room.

79. The REHAB CENTER also owed a duty to properly supervise its staff, but failed 

to properly supervise its employees and ensure that the employees were supervising the students, 

properly reporting bad acts, threats, and sexually harassing misconduct, and failed to develop 

proper protocol for reporting and taking actions through its supervisory procedures. Butler, the 

Superintendent, the physical education instructor, and all other staff were made aware of Ford’s 

comments and should have been properly trained to supervise to Ford in light of the imminent 

danger of sexual violence he posed, remove him from the school, or alert the proper authorities 

and would have prevented Ford from escalating his behavior to commit sexual battery on mentally 

disabled THOMAS.

80. The REHAB CENTER also failed to properly supervise its staff and students and 

to ensure bathrooms were closed during cleanings and/or ensuring that there was more than one 

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person cleaning the locker room at a time, and/or ensuring that women were protected while 

cleaning the men’s locker room.

81. The REHAB CENTER had actual knowledge of Ford’s past conduct and coupled 

with his comments, and it either knew or should have known that the danger Ford posed was 

imminent. Therefore, the injury to THOMAS was both foreseeable and preventable. But for the 

REHAB CENTER’s negligent acts and negligent failures to act, THOMAS would not have been 

subjected to the sexual abuse, harassment, assault, and battery, by Ford.

82. The REHAB CENTER’s numerous actions and omissions listed above, actually 

and proximately caused THOMAS’ sexual battery resulting in her ongoing and permanent injuries 

and damages. THOMAS was sexually abused and battered by Ford, a student within the custody, 

care and/or control of the REHAB CENTER due to the negligence of the REHAB CENTER agents 

and/or employees

83. As a direct and proximate cause of the REHAB CENTER’s breach of its numerous

duties owed to THOMAS, she sustained ongoing and permanent injuries and damages. THOMAS

was subjected to sexual abuse, sexual battery, and endured emotional distress, severe 

psychological injuries, humiliation, mental anguish, which has manifested into episodes of acting 

out, restlessness, anxiety; shock and fright; embarrassment; loss of everyday social pleasures and 

enjoyment; and other injuries and disablements which have yet to manifest themselves at this time 

which have all resulted in medical bills, loss of future earning potential, as well as other 

expenditures that will be incurred in the future.

84. WHEREFORE, Plaintiff CHASSITY THOMAS, by and through her legal 

guardian, NINA PHILLIPS, demands judgment for damages against Defendant REHAB CENTER 

in excess of the jurisdictional limits of this court, together with interest, attorneys’ fees and costs.

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COUNT VIII

GENERAL NEGLIGENCE, NEGLIGENT TRAINING AND NEGLIGENT 

SUPERVISION AGAINST DEFENDANT JVS AND DEFENDANT JVM

85. Plaintiff incorporates paragraphs 1 through 27 as if fully stated herein.

86. JVS and JVM were in the practice of placing people with disabilities into several 

different assignments with different facilities. JVS and JVM had actual prior knowledge of 

THOMAS’ disability as well as her verbal impairments. 

87. This prior knowledge of THOMAS’ disability put the agents and/or staff at JVS on 

notice that THOMAS’ placement would require extra responsibility in determining that it was 

adequately safe for THOMAS to work there. 

88. Despite JVS and JVM’s knowledge of the circumstances surrounding THOMAS’

disability and without regard to her safety, JVS and JVM placed THOMAS to work at a facility 

without any investigation into the facility’s safety record, safety policies, and/or any investigation 

as to the students that were matriculated at the REHAB CENTER.

89. JVS and JVM failed to require that the REHAB CENTER notify JVS and JVM

when students or persons on its property and/or in their custody and/or control had criminal records 

or posed a threat of sexual and/or physical violence to others. 

90. JVS had a duty to properly screen the locations in which it placed its employees to 

ensure their safety. In addition, JVS and JVM specifically placed THOMAS at the REHAB 

CENTER as a janitor in the men’s locker room without any safety requirements, policies and/or 

procedures that would ensure THOMAS’ safety. 

91. JVS and JVM failed to take reasonable and adequate safety and security measures 

to prevent the sexual abuse of their employees and/or staff. JVS and JVM failed to implement 

policies and/or procedures to keep mentally disabled employees safe and/or to prevent their 

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exposure to sexual battery and physical violence during the course and scope of their employment. 

JVS failed to take reasonable safety and security measures to protect THOMAS during her 

employment and prevent an attack on her person that resulted in her sexual abuse and battery. 

92. JVS and JVM failed to properly train and supervise its employees and/or agents 

who place the job assignments, including its employee that assigned THOMAS to work at the 

REHAB CENTER. 

93. THOMAS was assigned to work at the REHAB CENTER through JVS and JVM, 

and therefore JVS and JVM had an affirmative duty to protect all persons, especially its visually 

and mentally impaired employees from the sexual harassment, abuse, assault, and sexual battery 

she sustained at the facility. JVS and JVM knew that their employees who were providing 

cleaning services were mentally disabled persons, and JVS and JVM negligently failed to 

take measures to train and/or supervise their employees to ensure THOMAS’ safety while

she cleaned the men’s locker room unsupervised, and did nothing to protect THOMAS from 

the foreseeable and preventable sexual abuse. 

94. Despite prior knowledge and notice, JVS and JVM negligently assigned THOMAS

to clean the men’s locker room without supervision, and at the time THOMAS was assigned to 

perform janitorial services at the REHAB CENTER, both JVS and JVM failed in the following 

duties owed to Plaintiff Chassity Thomas:

(a) failed to implement safety precautions for THOMAS;

(b) failed to properly train its employees and/or agents in procedures that would assure 

the safety of its disabled employees while assigned at other facilities and prevent 

sexual misconduct;

(c) failed to implement policies and/or procedures that would prevent such misconduct;

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(d) failed to implement policies and/or procedures to ensure that the REHAB CENTER

had a policy to require the locker room to be vacant while it was being cleaned;

(e) failed to provide THOMAS with signs to close the restroom, or objects to place in 

the doorway to obstruct entrance to the bathroom during cleaning, since they were 

aware that THOMAS, a disabled woman was assigned to clean it;

(f) failed to establish a policy that required the supervision of its own employees, 

especially the mentally disabled persons that were assigned to clean the locker room 

of the opposite sex;

(g) failed to promulgate adequate policies and procedures to protect its employees with 

known disabilities;

(h) failed to require the REHAB CENTER to report any person on its premise with a 

known criminal history and/or any known sexual misconduct to JVS for the safety 

of its employees;

(i) failed to require more than one employee clean the restroom together for safety, 

knowing that generally the employees who worked as janitors inside the facility are 

disabled; and 

(j) such other negligence as may be revealed through discovery.

95. JVS and JVM’s numerous actions and omissions listed above, actually and 

proximately caused THOMAS’ sexual battery resulting in her ongoing and permanent injuries and 

damages. THOMAS was negligently placed on the premises of the REHAB CENTER by JVS and 

JVM. THOMAS was sexually abused and battered by Ford, a student within the custody, care 

and/or control of the REHAB CENTER due to the negligence of the JVS and JVM’s agents and/or 

employees, who negligently placed THOMAS inside the REHAB CENTER as a janitor.

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96. As a direct and proximate cause of JVS and JVM’s breach of its numerous duties 

owed to THOMAS, she sustained ongoing and permanent injuries and damages. THOMAS was 

subjected to sexual abuse, sexual battery, and endured emotional distress, severe psychological 

injuries, humiliation, mental anguish, which has manifested into episodes of acting out, 

restlessness, anxiety; shock and fright; embarrassment; loss of everyday social pleasures and 

enjoyment; and other injuries and disablements which have yet to manifest themselves at this time 

which have all resulted in medical bills, loss of future earning potential, as well as other 

expenditures that will be incurred in the future.

97. WHEREFORE, Plaintiff CHASSITY THOMAS, by and through her legal 

guardian, NINA PHILLIPS, demands judgment for damages against Defendants JVS and JVM in 

excess of the jurisdictional limits of this court, together with interest, attorneys’ fees and costs.

COUNT IX

SEXUAL BATTERY AGAINST DEFENDANT FORD

98. Plaintiff incorporates paragraphs 1 through 27 as if fully stated herein.

99. Defendant FORD was an adult male.

100. On June 27, 2019, Defendant FORD attacked Plaintiff CHASSITY THOMAS 

while she was performing janitorial services in the men’s locker room at Defendant REHAB 

CENTER, and penetrated her vagina and her anus with his penis, constituting unwanted touching 

of her person and unwanted sexual penetration against Plaintiff THOMAS’ will.

101. Plaintiff THOMAS did not consent to any form of sexual contact; and, she lacked 

legal capacity to consent sexual activity due to her mental disability, including but not limited to, 

down syndrome. Plaintiff THOMAS mental disability was obvious and known to Defendant 

FORD.

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102. As a result, Defendant FORD committed an unwanted sexual battery upon Plaintiff 

THOMAS actually and proximately causing her to suffer ongoing and permanent injury and 

damages, including but not limited to: THOMAS was subjected to sexual abuse, sexual battery, 

and endured emotional distress, severe psychological injuries, humiliation, mental anguish, which 

has manifested into episodes of acting out, restlessness, anxiety; shock and fright; embarrassment; 

loss of everyday social pleasures and enjoyment; and other injuries and disablements which have 

yet to manifest themselves at this time which have all resulted in medical bills, loss of future 

earning potential, as well as other expenditures that will be incurred in the future.

COUNT X

SEXUAL BATTERY AGAINST REHAB CENTER

103. Plaintiff incorporates paragraphs 1 through 27 as if fully stated herein.

104. At all times material hereto, Defendant REHAB CENTER as a residential facility 

had care, custody, and control of Defendant FORD, a visually impaired adult male recently 

released from prison.

105. Despite having actual knowledge of Defendant FORD’s criminal history, and the 

fact that threat of sexual violence he posed to others was imminent, as he sexually harassed persons 

on the campus by making verbal sexualized statements about the fact that he was seeking sexual 

intercourse that was known to supervisors, Defendant REHAB CENTER did not properly 

supervise him and/or remove him from the property for the safety of other persons including 

Plaintiff. On June 27, 2019, Defendant FORD attacked Plaintiff CHASSITY THOMAS while 

she was performing janitorial services in the men’s locker room at Defendant REHAB CENTER, 

and penetrated her vagina and her anus with his penis, constituting unwanted touching of her 

person and unwanted sexual penetration against Plaintiff THOMAS’ will. At all material times 

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during the subject incident, Defendant FORD was in the care, custody, and/or control of Defendant 

REHAB CENTER.

106. Plaintiff THOMAS did not consent to any form of sexual contact; and, she lacked 

legal capacity to consent sexual activity due to her mental disability, including but not limited to, 

down syndrome. Plaintiff THOMAS’ mental disability was obvious and known to Defendant 

FORD. 

107. As a result, Defendant FORD committed an unwanted sexual battery upon Plaintiff 

THOMAS for which DEFENDANT REHAB CENTER is liable, actually and proximately causing 

her to suffer ongoing and permanent injury and damages, including but not limited to: THOMAS

was subjected to sexual abuse, sexual battery, and endured emotional distress, severe 

psychological injuries, humiliation, mental anguish, which has manifested into episodes of acting 

out, restlessness, anxiety; shock and fright; embarrassment; loss of everyday social pleasures and 

enjoyment; and other injuries and disablements which have yet to manifest themselves at this time 

which have all resulted in medical bills, loss of future earning potential, as well as other 

expenditures that will be incurred in the future.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff CHASSITY THOMAS, by and through her legal guardian NINA 

PHILLIPS, individually respectfully requests that this Court award the following damages, jointly 

and severally against Defendants, REHAB CENTER, JVS, JVM, and FORD as provided by the 

Illinois law, including but not limited to the following:

(a) Award compensatory damages to Plaintiff;

(b) Award reasonable attorneys’ fees and costs to Plaintiff;

(c) Loss of past and future support and services with interest;

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(d) Loss of past and future earnings;

(e) Punitive damages;

(f) Any and all relief pursuant to 42 U.S.C. Section 1988

(g) Any and all other and further relief as this Court may deem appropriate.

TRIAL BY JURY

 WHEREFORE, Plaintiff CHASSITY THOMAS, by and through her legal 

representative, NINA PHILLIPS, hereby demands a trial by jury on all issues so triable.

DATED this _____ day of June 2020. 

Respectfully Submitted,

_/s/ Lester Barclay________

Lester Barclay, Esquire

ARDC#: 61894868

THE BARCLAY LAW GROUP, P.C.

111 W Washington Street #1042

Chicago, IL 60602

(312) 553-0123 Telephone

(312) 553-0127 Facsimile

Attorney for Plaintiff

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