Plaintiff, the United States of America, alleges:

1. This action is brought on behalf of the United States to enforce the provisions of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. 2000e, et seq.
2. This Court has jurisdiction of the action under 42 U.S.C.  2000e-5(f) and 28 U.S.C.  1345.
3. Defendant, the City of Winter Springs, Florida ("Winter Springs") is a municipality located in Seminole County, Florida, and is a political subdivision of the State of Florida.
4. Winter Springs operates a fire department, in which it employs individuals as firefighters, paramedics and in other positions.
5. Winter Springs is an employer within the meaning of 42 U.S.C.  2000e(b).
6. Stacey Goodbread was hired by Winter Springs as probationary firefighter in its fire department on or about March 1, 1993.
7. At all relevant times, Stacey Goodbread has practiced Branhamism, which is a fundamentalist Christian religion.
8. At all relevant times, among the religious observances, practices and/or beliefs of Mr. Goodbread were not displaying or participating in the display of decorations commonly associated with Christmas, not watching television, wearing conservative dress in public, and daily reading of the Bible and listening to religious audio tapes.
9. Winter Springs, through Mr. Goodbread's supervisors, was aware of Mr. Goodbread's religious observances, practices and/or beliefs, including Mr. Goodbread's religious observance, practice and/or belief of not displaying or participating in the display of decorations commonly associated with Christmas.
10. In spite of this knowledge, on or about December 2, 1993, Mr. Goodbread was ordered by a supervisor to prepare Christmas decorations for display at the fire station to which he was assigned.
11. After complying with the order, Mr. Goodbread told his supervisors that he did not want to take part in any other activities dealing with Christmas decorations because those activities were against his religion.
12. Mr. Goodbread was formally disciplined by a supervisor for his objections to being required to prepare Christmas decorations.
13. Mr. Goodbread was discharged or constructively discharged from employment as a probationary firefighter with Winter Springs on or about December 15, 1993.
14. Winter Springs has discriminated against Stacey Goodbread in violation of Section 703(a) of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C.  2000e-2(a), among other ways, by (a) failing and refusing reasonably to accommodate his religious observances, practices and/or beliefs; and (b) discharging or constructively discharging him from employment as a probationary firefighter because of his religion.
15. The United States Equal Employment Opportunity Commission ("EEOC") received a timely charge from Mr. Goodbread in which he alleged that he had been discriminated against in employment on the basis of his religion by the City of Winter Springs Fire Department.
16. Pursuant to Section 706 of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C.  2000e-5, the EEOC investigated the charge and found reasonable cause to believe that discrimination in employment against Mr. Goodbread on the basis of his religion, in violation of Title VII, had occurred. The EEOC attempted unsuccessfully to achieve through conciliation a voluntary resolution of the charge, and subsequently referred the charge to the Department of Justice.
17. All conditions precedent to the filing of this suit have been performed or have occurred.

WHEREFORE, Plaintiff prays that the Court grant the following relief:

(a) Enjoin the Defendant from failing and refusing to provide sufficient equitable relief to make whole the charging party, Stacy Goodbread, for the loss he has suffered as a result of the discrimination against him as alleged in this Complaint;

(b) Award compensatory damages to Stacy Goodbread as would fully compensate him for injuries caused by the discrimination against him as alleged in this Complaint, pursuant to and within the statutory limitations of Section 102 of the Civil Rights Act of 1991, 42 U.S.C.  1981a.

The plaintiff prays for such additional relief as justice may require, together with its costs and disbursements in this action.

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JURY DEMAND

The United States hereby demands a trial by jury of all issues so triable pursuant to Rule 38 of the Federal Rules of Civil Procedure and Section 102 of the Civil Rights Act of 1991, 42 U.S.C. 1981a.

JANET RENO
Attorney General

_____________________________
BILL LANN LEE Acting Assistant Attorney General
Civil Rights Division

William B. Fenton
David J. Palmer
Attorneys
Employment Litigation Section
Civil Rights Division
U. S. Department of Justice
Post Office Box 65968
Washington, DC 20035-5968
(202) 616-5570
Fax: (202) 514-1005

CHARLES R. WILSON
United States Attorney

By

Edward L. White III
Assistant United States Attorney
Florida Bar Number 893773
201 Federal Building
80 North Hughey Avenue
Orlando, Florida 32801
(407) 648-7500
Fax: (407) 480-7643