1
10
3
-
https://nchb2history.omeka.chass.ncsu.edu/files/original/9bc1e0e95a98bb99b55a5b02b54f88e2.jpg
689192944e811dd3c71ae629af84f149
Dublin Core
The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/.
Title
A name given to the resource
Eagle White Art Project Collection
Subject
The topic of the resource
Memes and other visual items created by Eagle White in protest of HB2
Description
An account of the resource
Eagle White created a number of memes and other digital collages in protest of HB2. He explains his work:
"I'm a Raleigh native, who attended high school at Broughton in Raleigh, and college at UNCG. A few weeks after graduating from college, I moved to Manhattan, where I tried to find a niche for myself.
After several years in New York, I returned to Raleigh, where I've been since. I live downtown, so I'm right in the middle of some of the crazy things which happen in NC government in Raleigh.
I've always been creative, and taught myself a bit of photo-manipulation technique using an online site. I had always used it to put my head/face into absurd situations/pictures, for the amusement of readers of my FB friends.
Then HB2 happened. As soon as I could find a copy of the bill (in its entirety) online, I read it, and realized the enormity of its scope, and the spiteful intention of those who passed it. In the days that followed, I became angry that it was being dealt with entirely as a "bathroom bill", when the other portions of the law were equally, if not more damaging.
I began making up graphics to post online (using my warped sense of humor, I called them "Art Projects.") It just took off from there. I moved the graphics from my personal page to several pages on FB which were created to express opposition to HB2 and the politicians who crafted and passed it.
The rest is history. Six months later, I can't believe how many of these things I've made and posted. I've had more than a few people say I was keeping the tradition of "political satire" alive and well on FB. I just wake up each day, read the news, and wait for my somewhat crazy mind/imagination to fill in the rest, for that day's "Art Project." I don't have television at home, so I get my news from online sources, and try to follow that good-ole rule we learned about writing term papers.....try to find at least two, and even better, three collaborating sources for information you use....."
Creator
An entity primarily responsible for making the resource
Eagle White
Date
A point or period of time associated with an event in the lifecycle of the resource
2016/00/00
Still Image
A static visual representation. Examples include paintings, drawings, graphic designs, plans and maps. Recommended best practice is to assign the type Text to images of textual materials.
Dublin Core
The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/.
Description
An account of the resource
May 2016: After the U.S. Department of Justice gave Gov. McCrory a deadline of May 9th to let them know that NC was in compliance with Federal anti-discrimination law, Governor McCrory whined that he was only given a few working days to make this happen. He seemed to forget that HB2 was introduced, passed by the legislature, and signed by him, all in the space of TWELVE HOURS. Since McCrory was headed for a showdown, a boxing card seemed appropriate. I found and modified a picture of an actual vintage boxing poster for this graphic.....
Title
A name given to the resource
Boxing Meme
Subject
The topic of the resource
McCrory and Department of Justice Boxing Match meme by Eagle White
Date
A point or period of time associated with an event in the lifecycle of the resource
2016/05/00
Boxing
Department of Justice
Eagle White
Memes
Pat McCrory
-
https://nchb2history.omeka.chass.ncsu.edu/files/original/57693620850ba68025e5c5c11d9915e0.jpg
59a61b920576f765c6548ff4dce4c83f
Dublin Core
The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/.
Title
A name given to the resource
Eagle White Art Project Collection
Subject
The topic of the resource
Memes and other visual items created by Eagle White in protest of HB2
Description
An account of the resource
Eagle White created a number of memes and other digital collages in protest of HB2. He explains his work:
"I'm a Raleigh native, who attended high school at Broughton in Raleigh, and college at UNCG. A few weeks after graduating from college, I moved to Manhattan, where I tried to find a niche for myself.
After several years in New York, I returned to Raleigh, where I've been since. I live downtown, so I'm right in the middle of some of the crazy things which happen in NC government in Raleigh.
I've always been creative, and taught myself a bit of photo-manipulation technique using an online site. I had always used it to put my head/face into absurd situations/pictures, for the amusement of readers of my FB friends.
Then HB2 happened. As soon as I could find a copy of the bill (in its entirety) online, I read it, and realized the enormity of its scope, and the spiteful intention of those who passed it. In the days that followed, I became angry that it was being dealt with entirely as a "bathroom bill", when the other portions of the law were equally, if not more damaging.
I began making up graphics to post online (using my warped sense of humor, I called them "Art Projects.") It just took off from there. I moved the graphics from my personal page to several pages on FB which were created to express opposition to HB2 and the politicians who crafted and passed it.
The rest is history. Six months later, I can't believe how many of these things I've made and posted. I've had more than a few people say I was keeping the tradition of "political satire" alive and well on FB. I just wake up each day, read the news, and wait for my somewhat crazy mind/imagination to fill in the rest, for that day's "Art Project." I don't have television at home, so I get my news from online sources, and try to follow that good-ole rule we learned about writing term papers.....try to find at least two, and even better, three collaborating sources for information you use....."
Creator
An entity primarily responsible for making the resource
Eagle White
Date
A point or period of time associated with an event in the lifecycle of the resource
2016/00/00
Still Image
A static visual representation. Examples include paintings, drawings, graphic designs, plans and maps. Recommended best practice is to assign the type Text to images of textual materials.
Dublin Core
The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/.
Description
An account of the resource
After U.S. Attorney General Loretta Lynch sent notice to NC that HB2 was in violation of existing Federal anti-discrimination law, Phil Berger spoke out against the DOJ and a Fourth Circuit ruling regarding a Virginia transgender student's rights at school.
Title
A name given to the resource
Phil Berger Speaks Out Meme
Subject
The topic of the resource
Phil Berger meme by Eagle White
Department of Justice
Memes
Phil Berger
-
https://nchb2history.omeka.chass.ncsu.edu/files/original/8f96f0176462254bb286c8634e7a6878.pdf
cf1547735266d72b55696663d054e7b8
PDF Text
Text
UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF NORTH CAROLINA
UNITED STATES OF AMERICA,
)
)
Plaintiff,
)
)
v.
)
)
STATE OF NORTH CAROLINA; PATRICK )
MCCRORY, in his official capacity as
)
Governor of North Carolina; NORTH
)
CAROLINA DEPARTMENT OF PUBLIC
)
SAFETY; UNIVERSITY OF NORTH
)
CAROLINA; and BOARD OF GOVERNORS )
OF THE UNIVERSITY OF NORTH
)
CAROLINA,
)
)
Defendants.
)
Case No. _____________
COMPLAINT
PRELIMINARY STATEMENT
1.
The United States files this complaint challenging a provision of North Carolina
law requiring public agencies to deny transgender persons access to multiple-occupancy
bathrooms and changing facilities consistent with their gender identity.
2.
As set forth below, Defendants’ compliance with and implementation of Part I of
North Carolina Session Law 2016-3, House Bill 2 (“H.B. 2”), which was enacted and became
effective on March 23, 2016, constitutes a pattern or practice of employment discrimination on
the basis of sex in violation of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C.
§ 2000e, et seq. (“Title VII”); discrimination on the basis of sex in an education program
receiving federal funds in violation of Title IX of the Education Amendments of 1972, 20 U.S.C.
§ 1681, et seq. (“Title IX”), and its implementing regulations, 28 C.F.R. Part 54 (2000), 34
C.F.R. Part 106 (2010); and discrimination on the basis of sex and gender identity in programs
1
Case 1:16-cv-00425 Document 1 Filed 05/09/16 Page 1 of 14
�receiving federal funds in violation of the Violence Against Women Reauthorization Act of 2013
(“VAWA”), 42 U.S.C. § 13925(b)(13).
JURISDICTION AND VENUE
3.
This Court has jurisdiction over this action pursuant to 42 U.S.C. § 2000e-6 and
28 U.S.C. §§ 1331, 1343(a), and 1345.
4.
Venue is proper pursuant to 28 U.S.C. § 1391(b) because Defendants are located
within the Middle District of North Carolina and because a substantial part of the acts or
omissions giving rise to this complaint arose from events occurring within this judicial district.
5.
This Court has the authority to enter a declaratory judgment and to provide
preliminary and permanent injunctive relief pursuant to Rules 57 and 65 of the Federal Rules of
Civil Procedure; 28 U.S.C. §§ 2201 and 2202; 42 U.S.C. §§ 2000e-6(a) and (b); 20 U.S.C. §
1682; and 42 U.S.C. §§ 13925(b)(13)(C) and 3789d(c)(3).
DEFENDANTS
6.
Defendant State of North Carolina is a person within the meaning of 42 U.S.C. §
2000e(a) and an employer within the meaning of 42 U.S.C. § 2000e(b).
7.
Defendant Patrick McCrory is the Governor of North Carolina. Pursuant to
Article III, Section 1 of the North Carolina Constitution, “the executive power of the State” is
vested in Defendant McCrory in his capacity as Governor. Article III, Section 5(4) also provides
that it is the duty of Defendant McCrory in his capacity as Governor to “take care that the laws
be faithfully executed.” Defendant McCrory is a person within the meaning of 42 U.S.C.
§ 2000e(a).
8.
Defendant North Carolina Department of Public Safety is an agency of the State
of North Carolina responsible for public safety, corrections and emergency management. It is a
-2-
Case 1:16-cv-00425 Document 1 Filed 05/09/16 Page 2 of 14
�person within the meaning of 42 U.S.C. § 2000e(a) and an employer within the meaning of 42
U.S.C. § 2000e(b). It is currently and, at all times relevant to the Complaint, has been a recipient
of federal funds from the Department of Justice’s Office on Violence Against Women, with open
grants dated after the reauthorization of VAWA on March 19, 2013. As a condition of receiving
federal funds, Defendant North Carolina Department of Public Safety signed contract assurances
agreeing that it will not discriminate in violation of federal law.
9.
Defendant University of North Carolina is a public, multi-campus university that
is organized under, and exists pursuant to, the laws of the State of North Carolina. It is a person
within the meaning of 42 U.S.C. § 2000e(a) and an employer within the meaning of 42 U.S.C.
§ 2000e(b). It is currently and, at all times relevant to the Complaint, has been a recipient of
federal funds from the United States Department of Justice, including the Office on Violence
Against Women, with open grants dated after the reauthorization of VAWA on March 19, 2013.
As a condition of receiving federal funds, Defendant University of North Carolina signed
contract assurances agreeing that it will not discriminate in violation of federal law.
10.
Defendant Board of Governors of the University of North Carolina is the
corporate body charged with the general control, supervision, and governance of the University
of North Carolina and is capable under North Carolina law of suing and being sued in any court.
FACTUAL ALLEGATIONS
Enactment of H.B. 2
11.
On March 23, 2016, the North Carolina legislature convened a special session for
the purpose of passing H.B. 2.
-3-
Case 1:16-cv-00425 Document 1 Filed 05/09/16 Page 3 of 14
�12.
H.B. 2 mandates, inter alia, that all “[p]ublic agencies . . . require multiple
occupancy bathrooms or changing facilities . . . be designated for and only used by individuals
based on their biological sex.” H.B. 2 defines “biological sex” as “[t]he physical condition of
being male or female, which is stated on a person’s birth certificate.” H.B. 2 further defines
“public agencies” to include, among other entities, the state executive, judicial and legislative
branches, including the University of North Carolina system.
13.
H.B. 2 was enacted in direct response to Ordinance 7056 passed by the City
Council in Charlotte, North Carolina (the “Charlotte Ordinance”), which permitted transgender
individuals to use facilities corresponding to their gender identity by prohibiting discrimination
based on “gender identity” in places of public accommodation.
14.
Governor McCrory and North Carolina legislators made explicit public statements
indicating that they proposed, passed, and signed H.B. 2 to overturn the Charlotte Ordinance and
to ensure transgender individuals would not be permitted to access bathrooms and other facilities
consistent with their gender identity in schools and other public agencies.
15.
Prior to the passage of the Charlotte Ordinance in February 2016, Governor
McCrory told members of the Charlotte City Council that the Ordinance could “create major
public safety issues by putting citizens in possible danger from deviant actions by individuals
taking improper advantage of a bad policy.” Governor McCrory went on to explain that the
“action of allowing a person with male anatomy, for example, to use a female restroom or locker
room will most likely cause immediate State legislative intervention which I would support as
governor.”
16.
When State Representative Dan Bishop introduced H.B. 2, he stated that “[a]
small group of far-out progressives should not presume to decide for us all that a cross-dresser’s
-4-
Case 1:16-cv-00425 Document 1 Filed 05/09/16 Page 4 of 14
�liberty to express his gender nonconformity trumps the right of women and girls to peace of
mind.”
17.
The bill passed both houses on March 23, 2016—the same day it was introduced.
Governor McCrory signed the bill that night. H.B. 2 took effect immediately.
18.
Following the conclusion of the special session, Senate President Phil Berger
stated on his website, “[t]he North Carolina Senate voted unanimously Wednesday [March 23,
2016] to stop a radical and illegal Charlotte City Council ordinance allowing men into public
bathrooms and locker rooms with young girls and women.” Senator Berger characterized the
Charlotte Ordinance as “dangerous” and claimed that it “created a loophole that any man with
nefarious motives could use to prey on women and young children.”
19.
Lieutenant Governor Dan Forest stated that the Charlotte Ordinance “would have
given pedophiles, sex offenders, and perverts free rein to watch women, boys, and girls undress
and use the bathroom.”
Defendants’ Compliance with and Implementation of H.B. 2 and the United States’
Response
20.
On April 5, 2016, following the enactment of H.B. 2, Defendant University of
North Carolina’s President, Margaret Spellings, issued a Memorandum to all Chancellors in the
University of North Carolina system, titled “Guidance – Compliance with the Public Facilities
Privacy & Security Act.” The Memorandum directed Chancellors that “University institutions
must require every multiple-occupancy bathroom and changing facility to be designated for and
used only by persons based on their biological sex.”
21.
As a federal funding agency, when the Department of Justice has reason to
question a funding recipient’s compliance with Title IX, it gives notice of non-compliance and
attempts to secure the recipient’s compliance through voluntary means.
-5-
Case 1:16-cv-00425 Document 1 Filed 05/09/16 Page 5 of 14
�22.
On April 8, 2016, the United States sent a letter to President Spellings seeking
information to determine whether the University was complying with federal law.
23.
In a response dated April 13, 2016, President Spellings affirmed that “the
University is specifically covered by H.B. 2 and is required as a public agency to comply with its
applicable portions, including the provisions related to multiple-occupancy bathrooms and
changing facilities.”
24.
On April 12, 2016, Governor McCrory issued Executive Order 93, implementing
H.B. 2 and affirming that “every multiple occupancy restroom, locker room or shower facility
located in a cabinet agency must be designated for and only used by persons based on their
biological sex.”
25.
Access to bathrooms and changing facilities on the University of North Carolina
campus are covered by the non-discrimination mandates of Title IX and VAWA.
26.
Access to bathrooms and changing facilities operated by Defendant North
Carolina Department of Public Safety and its sub-recipients are covered by the nondiscrimination mandate of VAWA.
27.
Access to bathrooms and changing facilities in the workplace at public agencies in
the State of North Carolina is a term, condition and privilege of employment and, therefore, is
covered by the non-discrimination mandate of Title VII.
28.
In letters dated May 4, 2016, the United States notified all Defendants, including
the University of North Carolina, that the United States had determined they were not in
compliance with Title VII, Title IX, and/or VAWA, based on their compliance with and
implementation of provisions of H.B. 2 that are irreconcilable with federal law. The United
States requested that Defendants immediately agree not to comply with those provisions of H.B.
-6-
Case 1:16-cv-00425 Document 1 Filed 05/09/16 Page 6 of 14
�2, ensure that transgender persons were entitled to use multiple-occupancy bathrooms and
changing facilities consistent with their gender identity as required by federal law, and retract
any statements to the contrary. The United States advised Defendants that it would take
enforcement action under the above statutes if such compliance with federal law was not
demonstrated.
29.
As of the filing of this Complaint, no Defendant has taken steps to achieve that
compliance.
Gender Identity and Its Relationship to Sex
30.
Individuals are typically assigned a sex on their birth certificate solely on the
basis of the appearance of the external genitalia at birth. Additional aspects of sex (for example,
chromosomal makeup) typically are not assessed and considered at the time of birth, except in
cases of infants born with ambiguous genitalia.
31.
An individual’s “sex” consists of multiple factors, which may not always be in
alignment. Among those factors are hormones, external genitalia, internal reproductive organs,
chromosomes, and gender identity, which is an individual’s internal sense of being male or
female.
32.
For individuals who have aspects of their sex that are not in alignment, the
person’s gender identity is the primary factor in terms of establishing that person’s sex. External
genitalia are, therefore, but one component of sex and not always determinative of a person’s
sex.
33.
Although there is not yet one definitive explanation for what determines gender
identity, biological factors, most notably sexual differentiation in the brain, have a role in gender
identity development.
-7-
Case 1:16-cv-00425 Document 1 Filed 05/09/16 Page 7 of 14
�34.
Transgender individuals are individuals who have a gender identity that does not
match the sex they were assigned at birth. A transgender man’s sex is male and a transgender
woman’s sex is female.
35.
A transgender individual may begin to assert a gender identity inconsistent with
their sex assigned at birth at any time from early childhood through adulthood. The decision by
transgender individuals to assert their gender identity publicly is a deeply personal one that is
made by the individual, often in consultation with family, medical and health care providers, and
others.
36.
Gender identity is innate and external efforts to change a person’s gender identity
can be harmful to a person’s health and well-being.
37.
Gender identity and transgender status are inextricably linked to one’s sex and are
sex-related characteristics.
38.
Most states authorize changing the sex marker on one’s birth certificate, but the
requirements for doing so vary and are often onerous. Specifically, many states require surgical
procedures. At least one state does not allow persons to change the sex marker on their birth
certificates.
39.
Individuals born in North Carolina must have proof of certain surgeries, such as
“sex reassignment surgery,” in order to change the sex marker on their birth certificates. N.C.
Gen. Stat. § 130A-118(b)(4).
40.
Surgery related to gender transitioning is generally unavailable to children under
41.
In addition, the great majority of transgender individuals do not have surgery as
age 18.
part of their gender transition. Determinations about such surgery are decisions about medical
-8-
Case 1:16-cv-00425 Document 1 Filed 05/09/16 Page 8 of 14
�care made by physicians and patients on an individual basis. For some, health-related conditions
or other medical criteria counsel against invasive surgery. For others, the high cost of surgical
procedures, which are often excluded from health insurance coverage, present an insurmountable
barrier.
42.
Standards of medical care for surgery related to gender transitioning generally
advise that transgender individuals present consistent with their gender identity on a day-to-day
basis across all settings of life, including in bathrooms and changing facilities at school and at
work, for a significant time period prior to undergoing surgery.
Impact of H.B. 2 on Transgender Individuals in North Carolina
43.
H.B. 2 requires public agencies to follow a facially discriminatory policy of
treating transgender individuals, whose gender identity may not match their birth certificates,
differently from similarly situated non-transgender individuals.
44.
Because of Defendants’ compliance with and implementation of H.B. 2, non-
transgender employees of Defendants and of other public agencies in North Carolina may access
bathrooms and changing facilities that are consistent with their gender identity in their places of
work, while transgender employees may not access bathrooms and changing facilities that are
consistent with their gender identity.
45.
Defendants’ compliance with and implementation of H.B. 2 stigmatizes and
singles out transgender employees, results in their isolation and exclusion, and perpetuates a
sense that they are not worthy of equal treatment and respect.
46.
Upon information and belief, transgender employees of Defendants and other
public agencies in North Carolina have suffered and continue to suffer injury, including, without
-9-
Case 1:16-cv-00425 Document 1 Filed 05/09/16 Page 9 of 14
�limitation, emotional harm, mental anguish, distress, humiliation, and indignity as a direct and
proximate result of Defendants’ compliance with and implementation of H.B. 2.
47.
Because of the compliance with and implementation of H.B. 2 by Defendants
University of North Carolina and Board of Governors of the University of North Carolina,
individuals who are not transgender may access campus bathrooms and changing facilities that
are consistent with their gender identity, while individuals who are transgender may not access
campus bathrooms and changing facilities that are consistent with their gender identity.
48.
The compliance with and implementation of H.B. 2 by Defendants University of
North Carolina and Board of Governors of the University of North Carolina stigmatizes and
singles out transgender individuals, results in their isolation and exclusion, and perpetuates a
sense that they are not worthy of equal treatment and respect.
49.
Upon information and belief, transgender individuals seeking access to the
University of North Carolina campus have suffered and continue to suffer injury, including,
without limitation, emotional harm, mental anguish, distress, humiliation, and indignity as a
direct and proximate result of compliance with and implementation of H.B. 2.
50.
Because of the compliance with and implementation of H.B. 2 by Defendants
North Carolina Department of Public Safety, University of North Carolina, and Board of
Governors of the University of North Carolina, individuals who are not transgender may access
bathrooms and changing facilities that are consistent with their gender identity in covered
facilities, while individuals who are transgender may not access bathrooms and changing
facilities that are consistent with their gender identity.
51.
The compliance with and implementation of H.B. 2 by Defendants North Carolina
Department of Public Safety, University of North Carolina, and Board of Governors of the
-10-
Case 1:16-cv-00425 Document 1 Filed 05/09/16 Page 10 of 14
�University of North Carolina stigmatizes and singles out transgender individuals seeking access
to covered facilities, results in their isolation and exclusion, and perpetuates a sense that they are
not worthy of equal treatment and respect.
52.
Upon information and belief, transgender individuals seeking access to covered
facilities have suffered and continue to suffer injury, including, without limitation, emotional
harm, mental anguish, distress, humiliation, and indignity as a direct and proximate result of
compliance with and implementation of H.B. 2.
CLAIMS FOR RELIEF
COUNT I
Violation of Title VII of the Civil Rights Act of 1964 (“Title VII”)
42 U.S.C. § 2000e, et seq.
(Against All Defendants)
53.
As alleged in this Complaint, Defendants State of North Carolina, North Carolina
Department of Public Safety, University of North Carolina, and Board of Governors of the
University of North Carolina are engaged in, and continue to engage in, a pattern or practice of
sex discrimination in the terms, conditions, and privileges of employment against their
transgender employees in violation Title VII.
54.
As alleged in this Complaint, Defendants State of North Carolina and Governor
McCrory have engaged in a pattern or practice of resistance to the full enjoyment of employment
rights under Title VII by implementing and requiring compliance with policies and practices that
require public agencies to discriminate against their transgender employees based on sex in the
terms, conditions, and privileges of employment in violation of Title VII.
-11-
Case 1:16-cv-00425 Document 1 Filed 05/09/16 Page 11 of 14
�COUNT II
Violation of Title IX of the Education Act Amendments of 1972 (“Title IX”)
20 U.S.C. § 1681, et seq.
(Against Defendants University of North Carolina and Board of Governors of the University of
North Carolina)
55.
As alleged in this Complaint, Defendants University of North Carolina and Board
of Governors of the University of North Carolina are discriminating on the basis of sex in
violation of Title IX.
COUNT III
Violation of the Violence Against Women Reauthorization Act of 2013 (“VAWA”)
42 U.S.C. § 13925(b)(13)
(Against Defendants North Carolina Department of Public Safety, University of North Carolina,
and Board of Governors of the University of North Carolina)
56.
As alleged in this Complaint, Defendants North Carolina Department of Public
Safety, University of North Carolina, and Board of Governors of the University of North
Carolina are discriminating on the basis of sex and gender identity, in violation of VAWA.
PRAYER FOR RELIEF
WHEREFORE, the United States respectfully requests that this Court:
A.
Declare that, by complying with and implementing H.B. 2’s provisions that apply
to multiple-occupancy bathrooms or changing facilities, Defendants discriminate on the basis of
sex in violation of Title VII;
B.
Declare that, by complying with and implementing H.B. 2’s provisions that apply
to multiple-occupancy bathrooms or changing facilities, Defendants University of North
Carolina and Board of Governors of the University of North Carolina discriminate on the basis
of sex in violation of Title IX;
-12-
Case 1:16-cv-00425 Document 1 Filed 05/09/16 Page 12 of 14
�C.
Declare that, by complying with and implementing H.B. 2’s provisions that apply
to multiple-occupancy bathrooms or changing facilities, Defendants North Carolina Department
of Public Safety, University of North Carolina, and Board of Governors of the University of
North Carolina discriminate on the basis of sex and gender identity in violation of VAWA;
D.
Issue a preliminary and permanent injunction to prevent further violations of
federal law; and
E.
Grant such additional relief as the needs of justice may require.
Dated: May 9, 2016
Respectfully submitted,
Vanita Gupta
Principal Deputy Assistant Attorney General
Civil Rights Division
United States Department of Justice
BY:
Delora L. Kennebrew
Chief
Employment Litigation Section
Civil Rights Division
United States Department of Justice
Shaheena A. Simons
Chief
Educational Opportunities Section
Civil Rights Division
United States Department of Justice
/s Corey Stoughton
Corey Stoughton NY Bar Number: 4152633
Attorney for Plaintiff
Senior Counsel
Civil Rights Division
United States Department of Justice
950 Pennsylvania Avenue, NW
MJB, Room 5642
Washington, DC 20530
Telephone: (202) 616-2124
E-mail: corey.stoughton@usdoj.gov
/s Ripley Rand
Ripley Rand NC Bar Number: 22275
Attorney for Plaintiff
United States Attorney
Middle District of North Carolina
United States Department of Justice
101 South Edgeworth Street, 4th Floor
Greensboro, NC 27401
Telephone: (336) 333-5351
E-mail: ripley.rand@usdoj.gov
Lori B. Kisch DC Bar Number: 491282
Attorney for Plaintiff
Special Litigation Counsel
Whitney M. Pellegrino DC Bar Number: 490972
Attorney for Plaintiff
Special Legal Counsel
-13-
Case 1:16-cv-00425 Document 1 Filed 05/09/16 Page 13 of 14
�Employment Litigation Section
Civil Rights Division
United States Department of Justice
950 Pennsylvania Avenue, NW
PHB Room 4605
Washington, DC 20530
Telephone: (202) 305-4422
E-mail: lori.kisch@usdoj.gov
Educational Opportunities Section
Civil Rights Division
United States Department of Justice
950 Pennsylvania Avenue, NW
PHB Room 4004
Washington, DC 20530
Telephone: (202) 514-4092
E-mail: whitney.pellegrino@usdoj.gov
Candyce Phoenix VA Bar Number: 80800
Attorney for Plaintiff
Senior Trial Attorney
Employment Litigation Section
Civil Rights Division
United States Department of Justice
950 Pennsylvania Avenue, NW
PHB, Room 4031
Washington, DC 20530
Telephone: (202) 616-3871
E-mail: candyce.phoenix@usdoj.gov
Torey B. Cummings MA Bar Number: 664549
Attorney for Plaintiff
Senior Trial Attorney
Educational Opportunities Section
Civil Rights Division
United States Department of Justice
950 Pennsylvania Avenue, NW
PHB, Room 4112
Washington, DC 20530
Telephone: (202) 514-4092
E-mail: torey.cummings@usdoj.gov
Sean Keveney TX Bar Number: 24033863
Attorney for Plaintiff
Trial Attorney
Housing and Civil Enforcement
Civil Rights Division
United States Department of Justice
950 Pennsylvania Avenue, NW
NWB, Room 7010
Washington, DC 20530
Telephone: (202) 514-4838
E-mail: sean.keveney@usdoj.gov
Dwayne J. Bensing DC Bar Number: 1012138
Attorney for Plaintiff
Trial Attorney
Educational Opportunities Section
Civil Rights Division
United States Department of Justice
950 Pennsylvania Avenue, NW
PHB, Room 4015
Washington, DC 20530
Telephone: (202) 616-2679
E-mail: dwayne.bensing@usdoj.gov
ATTORNEYS FOR THE UNITED STATES OF AMERICA
-14-
Case 1:16-cv-00425 Document 1 Filed 05/09/16 Page 14 of 14
�
Dublin Core
The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/.
Title
A name given to the resource
Organizational Documents
Subject
The topic of the resource
Organizational documents related to HB 2
Description
An account of the resource
While NC HB2: A Citizens' History focuses on materials that relate to individual experiences, this collection features organizational and government documents that help contextualize those experiences.
Creator
An entity primarily responsible for making the resource
Tammy Gordon
Text
A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text.
Dublin Core
The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/.
Title
A name given to the resource
Complaint USDOJ v. NC
Department of Justice