Case 4:21-cv-00686 Document 1 Filed on 03/02/21 in TXSD Page 13 of 82
they were not qualified to occupy. The Solis email string would soon prove true “preferential treatment” of Hispanics was going to be Maldonado’s racist agenda. Such a race-based policy is per se racist. 105.
Solis’s emails could be dismissed as the wishful thinking of Maldonado’s personal
friend except that, as Solis was an HCC director at the time, his emails indicate the extent and forethought dedicated to the general policy that led to HCC’s Displacement Plan, as well as his confidence in Maldonado’s preferential program for Hispanics. Moreover, Solis’s prediction has proven to be factually true. While Black employees in leadership and other roles have been uniformly reduced, less-trained and less-experienced Hispanics and Whites have flooded in to replace them. The events since Maldonado’s arrival only make sense when understood in the context of HCC’s scheme of racial discrimination and retaliation against Black employees. B. HCC s Racial Displacement Plan” to Discriminate Against Black Employees 106.
HCC’s board of trustees, in practice, has delegated their power and authority to
Maldonado, who in turn has admittedly assigned, delegated to, and acted in concert with his subordinates the right and authority to hire, investigate, discipline, and terminate the Black employees.5 Accordingly, Maldonado and the unsued defendants, Anderson and May, are and were the final decision-makers in many instances with respect to the employment policies and practices challenged in this suit. 107.
The common practices utilized by these executives yield one of three common
5
In another racial discrimination lawsuit filed by a former Black HCC executive, Maldonado confirmed under oath that he simply relies on and accepts the recommendations of his underlings like Janet May and Thomas Anderson in terminating, disciplining, and/or demoting employees. See Maldonado’s sworn deposition testimony in Cause No. 2015-77438, Dr. Sabrina Lewis v. Houston Community College, taken in the 269th District Court, Harris County, TX. While this testimony is not entirely true—because Maldonado himself instigated the directive by action and policy that Black executives are expendable—it is true that his directive is implemented with dispatch by May and Anderson to rid the College of experienced Black employees.
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