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UNITED STATES DISTRICT COURTFOR THE MIDDLE DISTRICT OF FLORIDA

Tampa Division

UNITED STATES EQUAL

EMPLOYMENT

OPPORTUNITY COMMISSION,

Plaintiff,

v.

LAKELAND EYE CLINIC, P.A.,

Defendant

§

§

§

§

§

§

§

§

§

CASE NO. 8:14-cv-2421-T35 AEP

UNOPPOSED MOTION OF BRANDI BRANSON TO

INTERVENE AS OF RIGHT AND JOIN CLAIMS AS PLAINTIFF

Brandi Branson (“Plaintiff/Intervenor”), by her undersigned counsel, moves pursuant to

Fed. R. Civ. P. 24(a) to intervene in this matter as plaintiff and moves pursuant to Fed. R.

Civ. P. 18 to join state law claims which form the same case or controversy, and state as

grounds thereof:

1. Plaintiff/Intervenor makes this Motion to Intervene pursuant to Fed. R. Civ. P. 24(a)

which provides that “[o]n a timely motion, the court must permit anyone to intervene

who: (1) is given an unconditional right to intervene by a federal statute.”

Plaintiff/Intervenor is granted an unconditional right to intervene in this action by

Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-5(f).

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2. Plaintiff/Intervenor also moves under Fed. R. Civ. P. 18 to join her state law claims

arising out of the same case or controversy under Article III of the United States

Constitution.

3. Plaintiff/Intervenor was previously employed by Defendant.

4. Plaintiff/Intervenor was terminated by Defendant, and thereafter timely filed a Charge

of Discrimination with the EEOC alleging that she was discriminated against in

violation of Title VII and other federal and state statutes.

5. After conducting an investigation, the EEOC determined that Defendant had

discriminated against Plaintiff/Intervenor in violation of Title VII and other federal

statutes.

6. The EEOC initiated this action against Defendant under the enforcement authority

granted it by Title VII to remedy what it had concluded were the illegal

discriminatory acts of Defendant against Plaintiff/Intervenor.

7.

As an aggrieved party, Plaintiff/Intervenor has a statutory right to intervene in this

action pursuant to 42 U.S.C. § 2000e-5(f)(1) (“[t]he person or persons aggrieved shall

have the right to intervene in a civil action brought by the Commission.”).

8. Under the Florida Civil Rights Act of 1992, Plaintiff/Intervenor has the right to

challenge Defendant’s discriminatory conduct under state employment

nondiscrimination laws which mirror Title VII. Wright v. Sanderstein Investments,

LLC , 914 F.Supp.2d 1273, 1286 (N.D. Fla. 2012) citing Woodham v. Blue Cross and

Blue Shield of Florida, Inc., 929 So.2d 891, 894 (Fla. 2002).


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9. Though the EEOC has enforcement authority granted to it by Title VII, these powers

are limited to enforcement of federal laws. This means that without joinder of

Plaintiff/Intervenor’s state law claims to this action she would have to pursue a

judicial proceeding in state court that would focus on the same common nucleus of

operative fact that Plaintiff/Intervenor would ordinarily expect to be tried in the same

judicial proceeding as enforcement of her rights under the Title VII action brought by

the EEOC.

10. Under Fed. R. Civ. P 24(a) a party has a right to intervene if the applicant has a

claim or interest in the case. Rule 24 reads in pertinent part:

[u]pon timely motion, the court must permit anyone to intervene who: (1)is given an unconditional right to intervene by a federal statute; or (2)

claims an interest relating to the property or transaction that is the subject

of the action, and is so situated that disposing of the action may as a practical matter impair or impede the movant's ability to protect its

interest, unless existing parties adequately represent that interest.

Fed. R. Civ. P. 24(a).

11. Intervention as of right under Rule 24(a)(2) must be granted when four

requirements are met: (1) the application to intervene is timely; (2) the applicant

has an interest relating to the property or transaction which is the subject of the

action; (3) the applicant is so situated that the disposition of the action, as a

practical matter, may impede or impair his ability to protect that interest; and (4)

the applicant's interest will not be represented adequately by the existing parties to

the suit. Fox v. Tyson Foods, Inc., 519 F.3d 1298, 1302-03 (11th Cir. 2008);


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District of Florida, the undersigned has conferred with counsel for the Defendant and is

authorized to represent that the Defendant does not oppose the entry of an order granting

this motion.

Dated: December 3, 2014

Respectfully submitted,

s/ J. Kemp Brinson

J.Kemp BrinsonThe Brinson FirmP.O. Box 582

Winter Haven, FL 33882

Phone: 863-288-0234Fax: 863-508-7684

Attorney for Plaintiff/Intervenor


Fla. Bar No. [email protected]

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CERTIFICATE OF SERVICE

I hereby certify that on December 3, 2014, I electronically filed the foregoing with theClerk of the Court by using the CM/ECF system, which will automatically serve all

counsel of record.


s/ J. Kemp BrinsonJ. Kemp BrinsonThe Brinson FirmP.O. Box 582Winter Haven, FL 33882Phone: 863-288-0234

Fax: 863-508-7684Attorney for Plaintiff/Intervenor


Fla. Bar No. [email protected]

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IN THE UNITED STATES DISTRICT COURTFOR THE MIDDLE DISTRICT OF FLORIDA

Tampa Division

UNITED STATES EQUAL

EMPLOYMENT

OPPORTUNITY COMMISSION,

Plaintiff,

v.

LAKELAND EYE CLINIC, P.A.,

Defendant.

§

§

§

§

§

§

§

§

§

§

CASE NO. 8:14-cv-2421-T35 AEP

BRANDI BRANSON’S

COMPLAINT IN INTERVENTION AND DEMAND FOR JURY TRIAL

This is an action under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq.,

Title I of the Civil Rights Act of 1991, 42 U.S.C. § 1981a et seq., and the Florida Civil

Rights Act of 1992, Fla. Stat. § 760.01 et seq., to correct unlawful employment practices

on the basis of sex and to provide appropriate relief to Brandi Branson (“Ms. Branson” or

“Plaintiff/Intervenor”) who was adversely affected by such practices. As alleged with

greater particularity below, Defendant Lakeland Eye Clinic, P.A. (“Lakeland Clinic” or

“Defendant”) terminated Ms. Branson, a transgender woman, because of sex.

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"

JURISDICTION AND VENUE

#$ This Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1331 because the

action is based on Title VII, 42 U.S.C. § 2000e, et seq., a federal statute, pursuant to

28 U.S.C. § 1337 because the action is based on a federal statute regulating

commerce, and pursuant to 28 U.S.C. § 1343 because the action is based on

deprivation of the Plaintiff/Intervenor’s right under color of state law as against a

federal law providing for equal rights

"$ This Court has supplemental jurisdiction pursuant to 28 U.S.C. §1367 because the

Florida Civil Rights Act claims form part of the same case or controversy under

Article III of the United States Constitution.

%$ Venue is proper in the United States District Court for the Middle District of Florida

pursuant to 28 U.S.C. §§ 1391(b)(2) because a substantial part of the unlawful

employment practices are alleged to have been committed in Lakeland, Polk County,

Florida, located within the United States District Court for the Middle District of

Florida.

&$ The United States District Court for the Middle District of Florida is the proper forum

in which to litigate the claims of Plaintiff/Intervenor because Defendant has a

physical presence in Lakeland, Polk County, Florida, and Ms. Branson has performed

all relevant work for Lakeland Clinic at that location.


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%

PARTIES

'$ Plaintiff the Equal Employment and Opportunity Commission (“EEOC” or

“Plaintiff”) is the agency of the United States of America charged with the

administration, interpretation, and enforcement of Title VII, and is expressly

authorized to bring this action by Section 706(f)(1) and (3) of Title VII, 42 U.S.C.

§2000e-5(f)(1) and (3).

($ Plaintiff/Intervenor is a citizen of the State of Florida and is a real party in interest.

Specifically, Plaintiff/Intervenor is the person who suffered the discrimination that is

the basis of the EEOC’s lawsuit against Defendant Lakeland Clinic.

)$ At all relevant times to this lawsuit, Defendant Lakeland Clinic has continuously been

a Florida professional corporation doing business in the State of Florida and the City

of Lakeland, and has continuously had at least 15 employees.

*$ At all relevant times to this lawsuit, Defendant Lakeland Clinic has continuously been

an employer engaged in an industry affecting commerce within the meaning of

Sections 701(b), (g), and (h) of Title VII, 42 U.S.C. §§ 2000e(b), (g), and (h).

STATEMENT OF FACTS

+$ Defendant employs seven physicians who perform refractive, corneal, and cataract

surgery and treat retinal diseases. It is owned by Dr. Kevin Dorsett, an

ophthalmologist.

#,$ In or about early 2010, Defendant decided to add a hearing division to the eye clinic.

Defendant hired Physicians Hearing Services, Inc. (“PHSI”), a staffing company that


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specializes in hearing services, to provide candidates for the position of Director of

Hearing Services. PHSI recommended Ms. Branson for the position.

##$

On or about July 6, 2010 Defendant interviewed and hired Ms. Branson as Director

of Hearing Services. At the time of hire, Ms. Branson presented as male (e.g., used a

traditionally male name, wore male attire, responded to male pronouns, and otherwise

appeared to conform to traditional male gender norms).

#"$ At the time of hire, Defendant’s written description of the Director of Hearing

Services position did not include responsibility for any specific sales target. Likewise,

Ms. Branson was not notified at the time of hire orally or otherwise that as Director of

Hearing Services she was responsible for a particular sales target.

#%$ Upon information and belief, at the time of hire and for the duration of Ms.

Branson’s tenure at Lakeland Clinic, Defendant’s employer-provided health care plan

included an explicit exclusion of all gender-affirming treatment for transgender

persons, including psychological, hormonal, and surgical care otherwise available to

nontransgender plan enrollees.

#&$ Ms. Branson provided hearing services to patients who were referred to her by

Defendant’s physicians, and these referrals were Ms. Branson’s only source of

patients.

#'$ Ms. Branson performed the duties of her position successfully.

#($ In or about late February 2011, Ms. Branson began wearing feminine attire to work,

including make-up and women’s tailored clothing. Ms. Branson observed that co-

workers snickered, rolled their eyes, and withdrew from social interactions with her in


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'

response to her changing appearance and female gender expression. This was based

on gender stereotyping. Defendant was made aware of this conduct.

#)$

In or about April 2011, Defendant’s managers, acting within the course of their

duties for Defendant, requested a meeting with Ms. Branson, wherein Defendant

confronted Ms. Branson about her changing appearance and female gender

expression. Ms. Branson then informed Defendant that she was undergoing a gender

transition from male to female and that she would be changing her first name to

Brandi.

#*$ Following this meeting, Defendant’s managers and employees made derogatory

comments about Ms. Branson’s gendered appearance, and the ostracism by Branson’s

co-workers intensified. This was based on gender stereotyping. Defendant was made

aware of this conduct.

#+$ From about April 2011, until her termination, all but one of Defendant’s physicians

stopped referring patients to Ms. Branson for hearing services, thereby depriving her

of her client base. This was based on animus due to Ms. Branson’s gender, gender

identity or expression, and/or gender transition.

",$ On or about April 2011, the Administrator of Lakeland Clinic, Janet Townsend,

indicated, by words and tone of voice to Ms. Branson and others that Townsend and

Defendant were not supportive of Ms. Branson’s gender transition. This was based on

gender stereotyping.


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(

"#$ Townsend also indicated that she and Lakeland Clinic considered Ms. Branson’s

appearance and gender expression to be problematic. This was based on gender

stereotyping.

""$ On or about April 2011, Townsend discussed Ms. Branson’s gender transition with

tech clinician Donna Martin, asking Martin “What do you think of this

Michael/Michele [ sic.] thing?” Townsend then indicated her disapproval of Branson’s

gender transition, warning Martin that “next time I’ll be more careful in my

interviewing skills.” This was based on gender stereotyping. Shortly thereafter,

Martin told Branson about the conversation with Townsend. Martin told Branson that,

based on her conversation with Townsend, both Townsend and the Defendant

disapproved of Branson’s gender transition and gender identity and expression.

"%$ On or about June 10, 2011, Townsend called a meeting with Ms. Branson. During

the meeting Townsend told Ms. Branson that she had failed to meet her sales targets.

Townsend went on to say that because of declining sales, Defendant was eliminating

the Director of Hearing Services position. Townsend told Ms. Branson that Defendant

would not hire an employee to replace her since it was closing its hearing services

division. However, no such sales targets existed or were communicated to Ms.

Branson prior to this meeting.

"&$ At the time of her termination, Ms. Branson was successfully performing the

expressly contracted duties of her position.

"'$ On or about August 2011, Defendant hired a replacement for Ms. Branson and

continued to operate its hearing services division. Ms. Branson was replaced by a


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)

male employee who was not a member of the same protected category as Ms.

Branson.

"($Defendant did not have a policy barring discrimination based on gender identity or

expression, transgender identity, or gender stereotyping.

")$ As a result of the foregoing, Ms. Branson suffered damages.

"*$ Within 300 days of the occurrences alleged herein, Brandi Branson timely filed a

charge with the EEOC and the Florida Commission on Human Relations alleging

violations of Title VII by Defendant Lakeland Clinic, and has exhausted her

administrative remedies. This suit is brought within one year of the administrative

determination of this case. All conditions precedent to the institution of this lawsuit

have been fulfilled.

CAUSES OF ACTION

COUNT 1:

The Defendant Subjected Plaintiff/Intervenor to Harassment and a

Hostile Work Environment in Violation of Title VII of the 1964 Civil

Rights Act and Title I of the Civil Rights Act of 1991.

"+$ Plaintiff/Intervenor realleges and incorporates by reference all allegations in

paragraphs 1–28.

%,$ Plaintiff/Intervenor incorporates by reference the allegations stated in paragraphs 1 –

28 of the Complaint filed by the United States Equal Employment Commission.


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*

%#$ Ms. Branson was subjected to harassment and a hostile working environment based

on her gender, gender identity and expression, and gender transition as detailed

above.

%"$ This harassment and hostile working environment was severe, based on the nature of

the harassment, including statements expressing animus towards her gender, gender

identity and expression, and gender transition during the 300 days prior to Ms.

Branson’s EEOC complaint, and prior statements as part of a continuing course of

conduct by Defendant and Defendant’s managers and employees, all of which were

designed to and were likely to humiliate her, and which did have that effect on Ms.

Branson.

%%$ This harassment and hostile working environment was pervasive during the 300 days

prior to Ms. Branson’s EEOC complaint, based on the many incidents of harassment,

including many negative statements about her gender, gender identity and expression,

and gender transition as well as prior statements and restrictions as part of a

continuing course of conduct by Defendant and Defendant’s managers and

employees, all of which were because of Ms. Branson’s gender, gender identity and

expression.

%&$ The effect of the harassment and hostile working environment complained of above

has been to deprive Ms. Branson of equal employment opportunities and otherwise

adversely affect her status as an employee because of her sex in violation of Title VII

and Title I of the Civil Rights Act of 1991.


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+

%'$ Defendant was on notice of said practices and hostile working environment because

Defendant’s managers, including Plaintiff/Intervenor’s direct supervisors, participated

in and witnessed said practices.

%($ Defendant was on notice of said practices and hostile working environment because

Defendant complained, orally and in writing, to Defendant’s managers regarding said

practices.

%)$ Defendant failed and refused to investigate and take prompt and effective action

regarding said practices.

%*$ Defendant failed and refused to investigate and take prompt and effective action to

stop the hostile working environment.

%+$ Ms. Branson was threatened with and subjected to tangible employment actions and

materially adverse employment actions by Defendant.

&,$ By creating, condoning and perpetuating a hostile work environment because of Ms.

Branson’s gender, gender identity, and gender expression Defendant has acted

intentionally, maliciously, and/or recklessly with regard to her legally protected

rights.

&#$ As a direct and proximate result of the acts complained of herein, Ms. Branson has

suffered and will continue to suffer loss of compensation and benefits, mental and

emotional distress, humiliation, loss of reputation, loss of enjoyment of life and other

pecuniary and non-pecuniary losses.


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#,

&"$ By reason of the discrimination suffered by Plaintiff/Intervenor, she is entitled to all

legal and equitable remedies available under Title VII, 42 U.S.C. § 2000e, et seq. and

Title I of the Civil Rights Act of 1991, 42 U.S.C. § 1981a.

COUNT 2:

The Defendant Subjected Plaintiff/Intervenor to Harassment and a

Hostile Work Environment in Violation of the Florida Civil Rights

Act of 1992.

&%$ Plaintiff/Intervenor realleges and incorporates by reference all allegations in

paragraphs 1–28.

&&$ Plaintiff/Intervenor incorporates by reference the allegations stated in paragraphs 1 –


&'$ Ms. Branson was subjected to harassment and a hostile working environment based

on her gender, gender identity and expression, and gender transition as detailed

above.

&($ This harassment and hostile working environment was severe, based on the nature of

the harassment, including statements expressing animus towards her gender, gender

identity and expression, and gender transition during the one year prior to Ms.

Branson’s administrative complaint, and prior statements as part of a continuing

course of conduct by Defendant and Defendant’s managers and employees, all of

which were designed to and were likely to humiliate her, and which did have that

effect on Ms. Branson.


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##

&)$ This harassment and hostile working environment was pervasive during the one year

prior to Ms. Branson’s administrative complaint, based on the many incidents of

harassment, including many negative statements about her gender, gender identity

and expression, and gender transition as well as prior statements and restrictions as

part of a continuing course of conduct by Defendant and Defendant’s managers and

employees, all of which were because of Ms. Branson’s gender, gender identity and

expression.

&*$ The effect of the harassment and hostile working environment complained of above

has been to deprive Ms. Branson of equal employment opportunities and otherwise

adversely affect her status as an employee because of her sex in violation of the

Florida Civil Rights Act of 1992, Fla. Stat. § 760.01 et seq.

&+$ Defendant was on notice of said practices and hostile working environment because

Defendant’s managers, including Plaintiff/Intervenor’s direct supervisors, participated

in and witnessed said practices.

',$ Defendant was on notice of said practices and hostile working environment because

Plaintiff/Intervenor and others complained, orally and in writing, to Defendant’s

managers regarding said practices.

'#$ Defendant failed and refused to investigate and take prompt and effective action

regarding said practices.

'"$ Defendant failed and refused to investigate and take prompt and effective action to

stop the hostile working environment.


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#"

'%$ Ms. Branson was threatened with and subjected to tangible employment actions and

materially adverse employment actions by Defendant.

'&$ By creating, condoning and perpetuating a hostile work environment because of Ms.

Branson’s gender, gender identity, and gender expression Defendant has acted


rights.

''$As a direct and proximate result of the acts complained of herein, Ms. Branson has




'($ By reason of the discrimination suffered by Plaintiff/Intervenor, she is entitled to all

legal and equitable remedies available under the Florida Civil Rights Act of 1992,

Fla. Stat. § 760.01 et seq.

COUNT 3:

The Defendant Wrongfully Terminated Plaintiff/Intervenor Because

of Her Gender, Gender Identity, and Gender Expression in Violation

of Title VII of the 1964 Civil Rights Act and Title I of the Civil Rights

Act of 1991.

')$ Plaintiff/Intervenor realleges and incorporates by reference all allegations in

paragraphs 1–28.

'*$ Plaintiff/Intervenor incorporates by reference the allegations stated in paragraphs 1 –



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#&

(&$ As described above, Defendant did not close the hearing services department.

('$ As described above, Defendant hired a male who conformed to traditional male

gender norms to replace Ms. Branson.

(($ By permitting and condoning Townsend’s decision to terminate Ms. Branson despite

Townsend’s past open ridicule of Ms. Branson’s gender, gender identity and

expression, and gender transition Defendant has acted intentionally, maliciously,

and/or recklessly with regard to her legally protected rights.

()$ By permitting and condoning Townsend’s decision to terminate Ms. Branson in part

or in whole because Ms. Branson did not meet personal sales targets that had not

previously existed or been communicated to Ms. Branson, Defendant has acted


rights.

(*$The reason given by Defendant for Ms. Branson’s termination was a pretext for sex

discrimination.

(+$Defendant’s decision to terminate Ms. Branson was because of her sex, and/or sex

was a motivating factor in the decision to terminate her.

),$ As a direct and proximate result of the acts complained of herein, Ms. Branson has





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#'

)#$ By reason of the discrimination suffered by Plaintiff/Intervenor, she is entitled to all

legal and equitable remedies available under Title VII, 42 U.S.C. § 2000e, et seq. and

Title I of the Civil Rights Act of 1991, 42 U.S.C. § 1981a.

COUNT 4:

The Defendant Wrongfully Terminated Plaintiff/Intervenor Because

of Her Gender, Gender Identity, and Gender Expression in Violation

of the Florida Civil Rights Act of 1992.

)"$ Plaintiff /Intervenor realleges and incorporates by reference all allegations in

paragraphs 1–28.

)%$ Plaintiff/Intervenor incorporates by reference the allegations stated in paragraphs 1 –


)&$ Ms. Branson’s coworkers and Defendant’s managers openly ridiculed her gender

identity and expression, appearance, and gender transition in the four month period

leading up to her termination.

)'$ Townsend, Ms. Branson’s direct supervisor, made repeated negative comments about

Ms. Branson’s gender, gender identity and expression as well as her gender transition

to Branson privately, to Ms. Branson when Defendant’s other employees were

present, as well as to Defendant’ employees when Ms. Branson was not present.

When Townsend made these disparaging remarks, she asserted that Defendant shared

the same opinion.

)($ As described above, direct supervisor Townsend indicated to one of Defendant’s

employees that she would be hyper vigilant in screening candidates for positions with


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#*

B.

C.

D.

E.

basis of gender, gender identity and expression, and gender

transition, including but not limited to discharging its trans employees

because of their gender, gender identity and expression, and gender

transition, any other employment practice which discriminates on the

basis of their protected status;

Order Defendant Lakeland Clinic to institute and carry out polices, practices,

and programs which provide equal employment opportunities for transgender

persons, and which eradicate the effects of past unlawful employment

practices;

Order Defendant Lakeland Clinic to make whole Brandi Branson, by

providing appropriate backpay with prejudgment interest, in amounts to be

determined at trial, and other affirmative relief necessary to eradicate the

effects of Defedant's unlawful employment practices, including but not

limited to, frontpay;

Order Defendant Lakeland Clinic to make whole Brandi Branson, by

providing compensation for past and future pecuniary losses resulting from

the unlawful employment practices described in paragraphs above, including

but not limited to job search expenses and medical expenses not covered by

the Employer’s employee benefit plan, in amounts to be determined at trial;

Order Defendant Lakeland Clinic to make whole Brandi Branson by providing

compensation for past and future nonpecuniary losses resulting from the

unlawful employment practices complained of, including but not limited to,


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#+

emotional pain and suffering, inconvenience, loss of enjoyment of life, and

humiliation, in amounts to be determined at trial;

F.

Order Defendant Lakeland Clinic to pay Brandi Branson punitive damages for

its intentional, malicious and/or reckless conduct described above, in amounts

to be determined at trial;

G. Grant such further relief as the Court deems necessary and proper in the

public interest; and

H. Award Plaintiff/Intervenor her costs of this action and reasonable and

necessary attorney’s fees.

JURY TRIAL DEMANDED

Plaintiff/Intervenor requests a jury trial on all questions of fact raised by her complaint.


Respectfully submitted,

s/ J. Kemp BrinsonJ. Kemp Brinson

The Brinson FirmP.O. Box 582

Winter Haven, FL 33882

Phone: 863-288-0234

Fax: 863-508-7684



Fla Bar No. [email protected]

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CERTIFICATE OF SERVICE

This is to certify that on this 3rd day of December, 2014, the forgoing Complaint in

Intervention was filed with the Clerk of Court using the CM/ECF system, and was served

upon counsel of record by all parties to this proceeding by electronic notification.


s/ J. Kemp BrinsonJ. Kemp BrinsonThe Brinson FirmP.O. Box 582

Winter Haven, FL 33882Phone: 863-288-0234Fax: 863-508-7684



Fla Bar No. [email protected]

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