Case 4:21-cv-00686 Document 1 Filed on 03/02/21 in TXSD Page 11 of 82
eliminated all together;2 e. the Black employee is then confronted with the trumped-up charges and resultoriented investigation and the findings in the “investigation” are then used to “pad” the employee’s personnel file for justification of further adverse employment actions against the Black employee; and f. if the Black employee refuses to confess to the false and/or exaggerated charge(s), or otherwise tries to expose the injustice of the charge (for example, by filing an EEOC complaint, filing or participating in litigation against the College, or whistleblowing), they suffer multiple indignities such as being placed on forced administrative leave, deprived of promotions, placed under the supervision of unqualified employees whom the Black employees actually first trained, and/or being left out of meetings and ultimately terminated from their employment. 100.
HCC’s Displacement Plan for Blacks has been so flagrantly used it has resulted in
the displacement of 90% of the Black top level executives/professionals who were at HCC when Maldonado came on as chancellor. Compared to the number of veteran Black employees who have been “transformed” or terminated out of their positions since Maldonado arrived, only 10% of comparably-positioned White professionals have been displaced. Additionally, there has been a 50% increase in Hispanic hires and promotions to top level positions since Maldonado’s arrival— many of which Hispanic hires and promotions were made to less qualified and less-experienced candidates. 101.
White and Hispanic employees are not systematically displaced like Black HCC
employees. Indeed, their transgressions are routinely ignored and go unpunished while Black employees accused of lesser or the same transgressions are disciplined more harshly, sent home, placed on leave of absence, placed under “investigation,” and variously demeaned in the workplace. 102.
In less than six years at the helm of HCC, Maldonado’s racist regime has succeeded
2
Plaintiffs have evidence of HCC top-level officials requiring neutral or no-violation investigative findings against a Black employee being ordered to be changed to more negative findings even when facts do not support such findings.
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