Plaintiff Melody Dancer Samuels is a resident of Houston, Harris County, Texas

policies. The change to her employment was supposed only to be a title change, not a duty change,

but she found herself having a far more reduced role. Ms. Mims has been with HCC since 2014.

Her managerial duties were taken away and she was replaced by a younger, unqualified individual

despite the fact that Ms. Mims was ably performing the position. Ms. Mims has conducted her

duties faithfully and diligently; nevertheless, she faces continual harassment and retaliation in

order to force her to resign or face inevitable termination. The retaliation started when Ms. Mims

took several cases to compliance. Several were out of compliance – one such program was the

apprenticeship; the teachers teaching in the name of HCC were not properly credentialed. When

Ms. Mims tried to address these issues with her supervisor, she was taken out of the loop and had

her managerial duties removed and given to other white and Hispanic employees. One of the

concerns of the director is that they did not want them going through HR because a lot of the white

and Hispanic teachers would not pass qualification and background checks. In another case – Alix

Alvarado, a Hispanic HR employee, knew teachers were not credentialed. Her subordinate took

the class and her certificate was not accepted by the state b/c the instructor was not credentialed.

Instructors were being paid to credential. Johnny Sexton then started giving more of Ms. Mims

work to a Hispanic female to do. Ms. Mims remains in constant fear of being unjustly harassed

untilsheisterminated,similartotheconducttowhichotherBlackindividualshavebeensubjected.

Ms. Mims has witnessed the advancement of unqualified Hispanics to management and leadership

levels, where they have created hostile work environment, particularly towards herself and other

Black individuals. Because Ms. Mims chose to do her job correctly which in turn upset the apple

cart and potentially lead to the disqualification of improperly placed white and Hispanic

instructors, Ms. Mims was thenfaced with retaliation and areduction inresponsibility.Whenother

Hispanic and white employees at HCC do their jobs capably, they are rewarded and promoted, but