Case: 1:17-cv-06580 Document #: 1 Filed: 09/12/17 Page 1 of 19 PageID #:1

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
TAMI HAUKEDAHL and
WILLIAM POWELL
Plaintiffs,
v.
ELGIN COMMUNITY COLLEGE,
a not-for-profit corporation,
Defendant.

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Case No. 17-cv-6580

JURY TRIAL DEMANDED

COMPLAINT
Plaintiffs, Tami Haukedahl (“Haukedahl”) and William Powell (“Powell,” with
Haukedahl and Powell collectively referred to as “Plaintiffs”), by their attorneys, Peter M.
Katsaros, Esq. and Ashley L. Orler, Esq. of Golan Christie Taglia LLP, complain against
Defendant, Elgin Community College (“Defendant” or “ECC”), as follows:
Nature of Action
1.

This lawsuit arises under Title VII of the Civil Rights Act of 1964 as amended, 42

U.S.C. § 2000e, et seq. (“Title VII”), for ECC’s discrimination against Haukedahl on the basis of
her gender, EEC’s discrimination against Powell on the basis of his race, and ECC’s retaliation
against Haukedahl and Powell after they complained of discriminatory treatment.
2.

This lawsuit also arises under the Age Discrimination in Employment Act, 29

U.S.C. § 621, et seq. (“ADEA”), for ECC’s discrimination against Haukedahl on the basis of her
age and ECC’s retaliation against Haukedahl after she complained of discriminatory treatment.
3.

This lawsuit also arises under the Equal Pay Act of 1963 as amended, 29 U.S.C.

§ 206(d), et seq. (“EPA”), for ECC’s discrimination against Haukedahl on the basis of her gender

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by paying wages to her at a rate less than the rate at which it pays male employees performing
substantially equal work.
Parties
4.

Haukedahl, at all times relevant to this dispute, worked and resided in this judicial

district.
5.

Powell, at all times relevant to this dispute, worked and resided in this judicial

district.
6.

Plaintiffs are current employees of Defendant who work for Defendant in this

judicial district.
7.

Defendant is an Illinois not-for-profit corporation with its principal place of

business at 1700 Spartan Drive, Elgin, Illinois.
Jurisdiction and Venue
8.

This Court has jurisdiction over Counts I through IV under the express provisions

of Title VII, § 2000e-5(f)(3) and 28 U.S.C. § 1331, over Counts V and VI under the express
provisions of the ADEA, 29 U.S.C. § 626(c)-(d) and 28 U.S.C. § 1331, and over VII under the
express provisions of the EPA, 29 U.S.C. § 216(b) and 28 U.S.C. § 1331.
9.

Venue is proper in the Northern District of Illinois, Eastern Division, pursuant to

28 U.S.C. § 1391, because all the significant events giving rise to the claims occurred in this
judicial district.
10.

Venue is also proper in the Northern District of Illinois, Eastern Division because

Defendant does business and has employees located within this judicial district.

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Factual Allegations
A. Haukedahl’s Employment with ECC
11.

Haukedahl has been employed by ECC from approximately February 2009

through the present.
12.

From February 2009 until April 2011, Haukedahl worked as ECC’s All Hazards

Manager.
13.

From April 2011 through the present, Haukedahl worked as an ECC Deputy Chief

of Police.
14.

From February 2009 through October 27, 2016, Haukedahl’s immediate

supervisor was ECC’s Chief of Police Emad Eassa (“Eassa”).
15.

From October 28, 2016 through April 28, 2017, Haukedahl’s immediate

supervisor was Richard Enyard.

From April 28, 2017 through the present, Haukedahl’s

immediate supervisor was interim Chief of Police Robert Duffy.
16.

Prior to her employment by ECC, Haukedahl served the Illinois State Police as a

State Trooper for twenty-seven (27) years, including serving as Illinois State Police Captain for
over six (6) years and Commander for approximately four (4) years.
17.

As Commander of the Illinois State Police, Haukedahl had supervisory

responsibility over 200 officers and a budget of $22 million.
18.

Haukedahl is female, and was born on June 17, 1958.

19.

Throughout her employment by ECC, Haukedahl received favorable feedback

regarding her job performance.
20.

Throughout her employment by ECC, Haukedahl performed her job duties

satisfactorily.

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21.

Throughout Haukedahl’s employment by ECC and on a daily basis, Eassa

directed at Haukedahl angry outbursts and rants full of demeaning comments toward women –
including Haukedahl – older workers, and African Americans.
22.

During Haukedahl’s employment by ECC, Eassa displayed a sexist cartoon in his

office, which was easily seen by Haukedahl, other employees, and visitors to the ECC police
department offices.
23.

Throughout Haukedahl’s employment by ECC, Eassa referred to women

employed by ECC and female ECC students in demeaning terms, including boasting how many
ECC female employees working in positions of authority were sexually attracted to Eassa.
24.

In the spring of 2016, while speaking with several ECC police officers, including

Haukedahl, Eassa said, “It all starts at the top. Dr. Sam [ECC’s President] is a weak leader. He
is intimidated by men. Just look . . . he surrounds himself with women. . . .” “. . . He is letting
women run the college and that’s why it’s all f—ked up.”
25.

During Haukedahl’s employment and at ECC police department meetings, Eassa

referred to female ECC administrators as the “bitches upstairs” and to females generally as “local
talent and scenery.”
26.

While the ECC police department investigated a sexual harassment complaint

filed by an ECC employee against a student, Eassa first inquired if the ECC employee was
attractive and then said that the ECC should stop hiring good-looking women to avoid the
problem.
27.

After Haukedahl returned from a three-day sick leave, Eassa referred to

Haukedahl and some of her colleagues as “older” and threatened to replace Haukedahl and other
“older” workers with younger officers.

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28.

ECC, including the statements made by and actions of Eassa, created and

maintained a hostile working environment for Haukedahl.
29.

Similarly-situated employees who were male, including but not limited to former

ECC Deputy Chief of Police Mark Hinchy (“Hinchy”) and current ECC Deputy Chief of Police
Larry Mason (“Mason”) were treated more favorably than Haukedahl.
30.

Haukedahl’s work load, which includes emergency management responsibilities,

grant writing responsibilities, unreasonable deadlines and work not within her position’s job
description, is nearly double that of similarly-situated male employees, including but not limited
to Hinchy and Mason.
31.

Haukedahl has been required to perform work during the evenings and weekends

while similarly-situated male employees, including but not limited to Hinchy and Mason, have
not been required to perform work during the evenings and weekends.
32.

On or around twelve occasions, Eassa has threatened to terminate Haukedahl’s

employment with ECC if she fails to perform the extra work load not assigned to similarlysituated male employees.
33.

Eassa has not threatened to terminate the employment of similarly-situated male

employees.
34.

Throughout Haukedahl’s tenure as ECC Deputy Chief of Police, ECC paid

Haukedahl less than her male colleagues performing substantially equal work, including but not
limited to Eassa.
B. ECC’s Retaliation against Haukedahl
35.

On August 15, 2016, Haukedahl met with ECC Police Officers Powell, David

Janusch, and Joseph Lullo and ECC’s Human Resources Director Richard Enyard (“Enyard”)

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and complained about the harassment and discrimination directed at her and other ECC
employees by ECC, including Powell.
36.

On August 31, 2016, Haukedahl met with Powell and Enyard to follow-up on her

August 15, 2016 complaints.
37.

On September 16, 2016, Haukedahl met with Enyard to complain about Eassa’s

deviation from ECC hiring practices to fill the Deputy Chief of Police position after Hinchy
retired from employment with ECC.
38.

After complaining about the harassment and discrimination directed at Haukedahl

and other employees, including Powell, by ECC and about Eassa’s deviation from ECC hiring
practices, ECC retaliated against Haukedahl.
39.

On August 23, 2016, Eassa told Haukedahl, “I always get my revenge. It may

take time, but I always get my revenge.”
40.

On August 24, 2016, Eassa told Haukedahl, “Take your best shot motherf—ker.

Go for it.”
41.

On September 15, 2016, Eassa assigned Haukedahl to the less-desirable second

shift for seven (7) weeks total.
42.

On September 23, 2016, 2016, Eassa extended Haukedahl’s assignment to the

less-desirable second shift by an additional week.
43.

Prior to Haukedahl’s complaints about the harassment and discrimination directed

at Haukedahl, Deputy Chiefs, including Haukedahl, were assigned to the second shift every other
week.

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44.

Similarly-situated male employees who did not complain about harassment or

discrimination were not assigned to the less-desirable second shift for consecutive weeks at a
time.
45.

After Haukedahl complained about the harassment and discrimination directed at

her and other employees by ECC and about Eassa’s deviation from ECC hiring practices, Eassa
ostracized Haukedahl. He excluded Haukedahl from professional meetings that she ordinarily
would attend as part of her job duties, would not speak directly to Haukedahl, would direct
Haukedahl’s work through Mason, and excluded Haukedahl from the hiring process for ECC
police officers. This conduct was intended to demean Haukedahl in the workplace.
C. Powell’s Employment with ECC
46.

Powell has been employed by ECC from May 2, 2010 through the present.

47.

From May 2, 2010 through the present, Powell worked as an ECC Police Officer.

48.

From May 2, 2010 through October 27, 2016, Powell’s supervisor was ECC’s

Chief of Police Emad Eassa (“Eassa”).
49.

From October 28, 2016 through April 28, 2017, Powell’s immediate supervisor

was Richard Enyard. From April 28, 2017 through the present, Powell’s immediate supervisor
was interim Chief of Police Robert Duffy.
50.

Prior to his employment by ECC, Powell served the Aurora Police Department for

over thirty (30) years, including serving as the Aurora Police Chief for three (3) years.
51.

As the Aurora Police Chief, Powell had supervisory responsibility over 300 police

officers, a total staff of 400 employees, and a budget of approximately $58 million.
52.

Prior to applying for employment with ECC, Powell spoke with Eassa about

applying for the open ECC Deputy Police Chief position.

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53.

Eassa discouraged Powell from applying for the open ECC Deputy Police Chief

position despite Powell’s outstanding qualifications.
54.

On or around the time Powell spoke with Eassa about the open ECC Deputy

Police Chief position, ECC hired Hinchy as the ECC Deputy Police Chief, who was less
qualified than Powell for the position.
55.

Powell is an African American male.

56.

Hinchy is a Caucasian male.

57.

Throughout his employment by ECC, Powell received favorable feedback

regarding his job performance.
58.

Throughout his employment by ECC, Powell performed his job duties

satisfactorily.
59.

Throughout Powell’s employment by ECC and on a daily basis, Eassa directed at

Powell angry outbursts and rants full of demeaning comments toward African Americans –
including Powell – women, and older workers.
60.

Eassa outbursts and rants included comments about “racist black b—hes,

motherf—kers, broads and b—hes.”
61.

Powell and other ECC employees were referred to by Eassa as “motherf—kers,

b—hes, and lazy, angry black men.”
62.

ECC, including the statements made by and actions of Eassa, created and

maintained a hostile working environment for Powell.
63.

On July 31, 2016, Hinchy retired as ECC’s Deputy Police Chief, creating an open

Deputy Police Chief position.

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64.

Even though Powell is qualified to be ECC’s Deputy Police Chief, ECC failed to

consider Powell or promote Powell to the open position for which he had applied.
65.

After Hinchy’s retirement, ECC hired Mason to fill the open Deputy Police Chief

position, who was less qualified than Powell for the position.
66.

Mason is a Caucasian male.

67.

When ECC hired Mason as Deputy Police Chief, Eassa deviated from ECC hiring

practices.
68.

The ECC Deputy Police Chief position pays at least $10,000.00 more annually

than the ECC Police Officer position.
69.

ECC has paid Powell less than similarly-situated non-African American

employees, including but not limited to Caucasian Police Officer Larry Brouk, who is paid
approximately $6,500.00 more than Powell even though he has less experience and tenure than
Powell. That salary discrimination was race-based.
D. ECC’s Retaliation against Powell
70.

On July 5, 2016, Powell sent an email to Eassa, the ECC Deputy Police Chiefs

and to ECC’s Human Resources Director Richard Enyard (“Enyard”) complaining about the
harassment and discrimination directed at him and other ECC employees, including Haukedahl,
by ECC.
71.

On August 15, 2016, Powell met with ECC Deputy Chief Haukedahl, Officer

David Janusch, Officer Joseph Lullo, and HR Director Enyard and complained about the
harassment and discrimination directed at him and other ECC employees by ECC.
72.

On August 31, 2016, Powell met with Haukedahl and Enyard to follow-up on his

August 15, 2016 complaints.

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73.

After complaining about the harassment and discrimination directed at Powell and

other employees by ECC, ECC retaliated against Powell.
74.

After complaining about the harassment and discrimination directed at Powell and

other employees by ECC, Eassa assigned Powell to work on Saturdays, which Powell normally
did not work, and would not speak directly to Powell, ostracizing Powell.
E. Plaintiffs’ Exhaustion of Administrative Remedies
75.

On August 15, 2016, Haukedahl submitted a complaint against Eassa under ECC

Administrative Procedure 3.403, alleging a hostile work environment, discrimination, and
retaliation.
76.

On March 20, 2017, ECC issued its Notices of Independent Investigator’s

findings and corrective action. Haukedahl appealed ECC’s decision on March 24, 2017, and
Eassa appealed ECC’s decision on March 27, 2017.
77.

On May 1, 2017, the Chair and Vice Chair of the ECC Board of Trustees

conducted hearings on Haukedahl’s and Eassa’s appeals, and on June 8, 2017, the Chair and
Vice Chair decided to uphold the Independent Investigator’s findings as to Haukedahl’s
allegations and reverse the Independent Investigator’s findings that Eassa violated provisions of
ECC Administrative Procedure 3.403.

In doing so, ECC approved and endorsed the

discrimination led by Eassa.
78.

On August 15, 2016, Powell submitted a complaint against Eassa under ECC

Administrative Procedure 3.403, alleging hostile work environment, discrimination, and
retaliation.

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79.

On March 20, 2017, ECC issued its Notices of Independent Investigator’s

findings and corrective action. Powell appealed ECC’s decision on March 24, 2017, and Eassa
appealed ECC’s decision on March 27, 2017.
80.

On May 1, 2017, the Chair and Vice Chair of the ECC Board of Trustees

conducted hearings on Powell’s and Eassa’s appeals, and on June 8, 2017, the Chair and Vice
Chair decided to uphold the Independent Investigator’s findings as to Powell’s allegations and
reverse the Independent Investigator’s findings that Eassa violated provisions of ECC
Administrative Procedure 3.403. In doing so, ECC approved and endorsed the discrimination led
by Eassa.
81.

On February 15, 2017, Plaintiffs each filed a Charge of Discrimination against

Defendant (“Charge of Discrimination”) with the United States Equal Employment Opportunity
Commission (“EEOC”). Copies of the Charges of Discrimination are attached as Exhibits A and
B.
82.

Haukedahl’s Charge of Discrimination alleges discrimination on the basis of

gender and age and retaliation against Defendant.
83.

Powell’s Charge of Discrimination alleges discrimination on the basis of race and

retaliation against Defendant.
84.

On August 29, 2017, each Plaintiff received a “right to sue” letter for their

respective Charge of Discrimination from the U.S. Department of Justice. Copies of the EEOC
“right to sue” letters are attached as Exhibits C and D.
85.

The “right to sue” letters provide each Plaintiff ninety (90) days from the date of

their receipt of their respective letter to bring a lawsuit. Plaintiffs filed this Complaint before the
expiration of the ninety (90) day period.

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86.

Plaintiffs have fully exhausted all of their administrative remedies.
Count I – Violation of Title VII of the Civil Rights Act of 1964

87.

Haukedahl incorporates paragraphs 1 through 45 and 75 through 86 as though

fully stated here.
88.

At all times material to this Complaint, ECC was an employer within the meaning

of Title VII, §2000e, and employed more than the statutory minimum of fifteen employees.
89.

ECC discriminated against Haukedahl on the basis of her gender, female, in

violation of §2000e-2.
90.

Similarly-situated male employees at ECC did not receive the same treatment as

Haukedahl.
91.

ECC, acting through Eassa, created a hostile working environment for Haukedahl

due to Haukedahl’s gender.
92.

ECC’s violations of Haukedahl’s rights under Title VII have caused her

significant emotional and monetary harm.
93.

ECC’s violations of Haukedahl’s rights under Title VII were willful.

WHEREFORE, Plaintiff, Tami Haukedahl, respectfully requests that this Court, after a
jury trial, enter judgment in her favor and against Defendant, Elgin Community College, and
award damages equal to:
(i)

all back pay and front pay lost as a result of failure to pay equal wages;

(ii)

compensatory damages;

(iii)

punitive damages;

(iv)

her attorneys’ fees and costs; and

(v)

such other and further relief as this Court deems just and proper under the
circumstances.

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Count II – Violation of Title VII of the Civil Rights Act of 1964
94.

Haukedahl incorporates paragraphs 1 through 45 and 76 through 86 as though

fully stated here.
95.

At all times material to this Complaint, ECC was an employer within the meaning

of Title VII, §2000e, and employed more than the statutory minimum of fifteen employees.
96.

ECC retaliated against Haukedahl for exercising her rights under Title VII.

97.

Similarly-situated, male employees at ECC who did not exercise their rights under

Title VII at ECC did not receive the same treatment as Haukedahl.
98.

ECC’s violations of Haukedahl’s rights under Title VII have caused her

significant emotional and monetary harm.
99.

ECC’s violations of Haukedahl’s rights under Title VII were willful.

WHEREFORE, Plaintiff, Tami Haukedahl, respectfully requests that this Court, after a
jury trial, enter judgment in her favor and against Defendant, Elgin Community College, and
award damages equal to:
(i)

all back pay and front pay lost as a result of failure to pay equal wages;

(ii)

compensatory damages;

(iii)

punitive damages;

(iv)

her attorneys’ fees and costs; and

(v)

such other and further relief as this Court deems just and proper under the
circumstances.

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Count III – Violation of Title VII of the Civil Rights Act of 1964
100.

Powell incorporates paragraphs 1 through 10 and 46 through 86 as though fully

stated here.
101.

At all times material to this Complaint, ECC was an employer within the meaning

of Title VII, §2000e, and employed more than the statutory minimum of fifteen employees.
102.

ECC discriminated against Powell on the basis of his race, African American, in

violation of §2000e-2.
103.

Similarly-situated non-African American employees at ECC did not receive the

same treatment as Powell.
104.

ECC, acting through Eassa, created a hostile working environment for Powell due

to Powell’s race.
105.

ECC’s violations of Powell’s rights under Title VII have caused him significant

emotional and monetary harm.
106.

ECC’s violations of Powell’s rights under Title VII were willful.

WHEREFORE, Plaintiff, William Powell, respectfully requests that this Court, after a
jury trial, enter judgment in his favor and against Defendant, Elgin Community College, and
award damages equal to:
(vi)

all back pay and front pay lost as a result of failure to pay equal wages and
for failure to promote him to ECC Deputy Police Chief;

(vii)

compensatory damages;

(viii) punitive damages;
(ix)

his attorneys’ fees and costs; and

(x)

such other and further relief as this Court deems just and proper under the
circumstances.

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Count IV – Violation of Title VII of the Civil Rights Act of 1964
107.

Powell incorporates paragraphs 1 through 10 and 46 through 86 as though fully

stated here.
108.

At all times material to this Complaint, ECC was an employer within the meaning

of Title VII, §2000e, and employed more than the statutory minimum of fifteen employees.
109.

ECC retaliated against Powell for exercising his rights under Title VII.

110.

Similarly-situated, non-African American employees at ECC who did not exercise

their rights under Title VII at ECC did not receive the same treatment as Powell.
111.

ECC’s violations of Powell’s rights under Title VII have caused him significant

emotional and monetary harm.
112.

ECC’s violations of Powell’s rights under Title VII were willful.

WHEREFORE, Plaintiff, William Powell, respectfully requests that this Court, after a
jury trial, enter judgment in his favor and against Defendant, Elgin Community College, and
award damages equal to:
(vi)

all back pay and front pay lost as a result of failure to pay equal wages and
for failure to promote him to ECC Deputy Police Chief;

(vii)

compensatory damages;

(viii) punitive damages;
(ix)

his attorneys’ fees and costs; and

(x)

such other and further relief as this Court deems just and proper under the
circumstances.

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Count V – Violation of Age Discrimination in Employment Act
113.

Haukedahl incorporates paragraphs 1 through 45 and 75 through 86 as though

fully stated here.
114.

At all times material to this Complaint, ECC was an employer within the meaning

of the ADEA, §630(b), and employed more than the statutory minimum of twenty employees.
115.

ECC discriminated against Haukedahl on the basis of her age in violation of

§623(a).
116.

Similarly-situated employees at ECC under the age of forty (40) did not receive

the same treatment as Haukedahl.
117.

ECC, acting through Eassa, created a hostile working environment for Haukedahl

due to Haukedahl’s age.
118.

ECC’s violations of Haukedahl’s rights under the ADEA have caused her

significant emotional and monetary harm.
119.

ECC’s violations of Haukedahl’s rights under the ADEA were willful.

WHEREFORE, Plaintiff, Tami Haukedahl, respectfully requests that this Court, after a
jury trial, enter judgment in her favor and against Defendant, Elgin Community College, and
award damages equal to:
(i)

all back pay and front pay lost as a result of failure to pay equal wages;

(ii)

liquidated damages;

(iii)

her attorneys’ fees and costs; and

(iv)

such other and further relief as this Court deems just and proper under the
circumstances.

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Count VI – Violation of Age Discrimination in Employment Act
120.

Haukedahl incorporates paragraphs 1 through 45 and 75 through 86 as though

fully stated here.
121.

At all times material to this Complaint, ECC was an employer within the meaning

of the ADEA, §630(b), and employed more than the statutory minimum of twenty employees.
122.

ECC retaliated against Haukedahl for exercising her rights under the ADEA.

123.

Similarly-situated employees at ECC who did not exercise their rights under the

ADEA at ECC did not receive the same treatment as Haukedahl.
124.

ECC’s violations of Haukedahl’s rights under the ADEA have caused her

significant emotional and monetary harm.
125.

ECC’s violations of Haukedahl’s rights under the ADEA were willful.

WHEREFORE, Plaintiff, Tami Haukedahl, respectfully requests that this Court, after a
jury trial, enter judgment in her favor and against Defendant, Elgin Community College, and
award damages equal to:
(i)

all back pay and front pay lost as a result of failure to pay equal wages;

(ii)

liquidated damages;

(iii)

her attorneys’ fees and costs; and

(iv)

such other and further relief as this Court deems just and proper under the
circumstances.

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Count VII – Violation of Equal Pay Act of 1963
126.

Haukedahl incorporates paragraphs 1 through 45 and 75 through 86 as though

fully stated here.
127.

At all times material to this Complaint, ECC was an employer within the meaning

of the EPA, § 203(d).
128.

ECC violated the EPA, § 206(d), by paying Haukedahl less than male employees

performing substantially equal work.
129.

Male employees at ECC who have the same skill, effort and responsibility needed

to perform the work as Haukedahl, performed under similar working conditions, were paid more
than Haukedahl in violation of the EPA, §206(d).
130.

ECC’s violations of the EPA caused Haukedahl significant monetary harm.

131.

ECC’s violations of the EPA were willful.

WHEREFORE, Plaintiff, Tami Haukedahl, respectfully requests that this Court, after a
jury trial, enter judgment in her favor and against Defendant, Elgin Community College, and
award damages equal to:
(xi)

all back pay lost as a result of the failure to pay equal wages;

(xii)

liquidated damages equal to the amount of back pay lost as a result of the
failure to pay equal wages;

(xiii) her attorneys’ fees and costs; and
(xiv)

such other and further relief as this Court deems just and proper under the
circumstances.

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September 12, 2017

Respectfully submitted,
Tami Haukedahl and William Powell,
Plaintiffs,

By:
/s/ Peter M. Katsaros
One of Their Attorneys
Peter M. Katsaros, Esq. (#3122661)
Ashley L. Orler, Esq. (#6297339)
GOLAN CHRISTIE TAGLIA LLP
70 W. Madison Street, Suite 1500
Chicago, Illinois 60602
(312) 263-2300
pmkatsaros@gct.law
alorler@gct.law

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