UNITED STATES DISTRICT COURT FOR THE
MIDDLE DISTRICT OF FLORIDA
UNITED STATES OF AMERICA,
THE CITY OF WINTER SPRINGS, FLORIDA,
Plaintiff, the United States of America, alleges:
- 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.
- This Court has jurisdiction of the action under
42 U.S.C. 2000e-5(f) and 28 U.S.C. 1345.
- 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.
- Winter Springs operates a fire department, in
which it employs individuals as firefighters, paramedics and in
- Winter Springs is an employer within the meaning
of 42 U.S.C. 2000e(b).
- Stacey Goodbread was hired by Winter Springs as
probationary firefighter in its fire department on or about March
- At all relevant times, Stacey Goodbread has
practiced Branhamism, which is a fundamentalist Christian
- 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.
- 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
- 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
- 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.
- Mr. Goodbread was formally disciplined by a
supervisor for his objections to being required to prepare
- Mr. Goodbread was discharged or constructively
discharged from employment as a probationary firefighter with
Winter Springs on or about December 15, 1993.
- 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.
- 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.
- 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.
- All conditions precedent to the filing of this
suit have been performed or have occurred.
WHEREFORE, Plaintiff prays that the Court grant the
(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
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.
BILL LANN LEE Acting Assistant Attorney General
Civil Rights Division
William B. Fenton
David J. Palmer
Employment Litigation Section
Civil Rights Division
U. S. Department of Justice
Post Office Box 65968
Washington, DC 20035-5968
Fax: (202) 514-1005
CHARLES R. WILSON
United States Attorney
Edward L. White III
Assistant United States Attorney
Florida Bar Number 893773
201 Federal Building
80 North Hughey Avenue
Orlando, Florida 32801
Fax: (407) 480-7643