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Barbie Complaint

WLBT

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7K views

Barbie Complaint

WLBT

Uploaded by

the kingfish
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
You are on page 1/ 6

Case 3:23-cv-03154-DPJ-ASH Document 1 Filed 12/13/23 Page 1 of 6

IN THE UNITED STATES DISTRICT COURT


SOUTHERN DISTRICT OF MISSISSIPPI
NORTHERN DIVISION

BARBIE BASSETT PLAINTIFF

VS. 3:23-cv-3154-DPJ-FKB
CAUSE NO. _________________________

GRAY MEDIA GROUP, INC.,


d/b/a WLBT-TV DEFENDANT

JURY TRIAL DEMANDED

COMPLAINT

This is an action to recover actual and punitive damages for discrimination based upon race

and to recover actual and liquidated damages for discrimination based upon age. The action is also

to declare Plaintiff’s noncompete to be void and unenforceable. The following facts support the

action:

1.

Plaintiff BARBIE BASSETT is an adult resident citizen of 117 Northlake Drive, Madison,

Mississippi 39110.

2.

Defendant GRAY MEDIA GROUP, INC., d/b/a WLBT-TV, is a Delaware corporation doing

business in the State of Mississippi. Defendant may be served with process by service upon its

registered agent, C T Corporation System, 645 Lakeland East Drive, Suite 101, Flowood, Mississippi

39232. Defendant is engaged in the media business.


Case 3:23-cv-03154-DPJ-ASH Document 1 Filed 12/13/23 Page 2 of 6

3.

This Court has federal question jurisdiction under 28 U.S.C. § 1331, and civil rights

jurisdiction under 28 U.S.C. § 1343, for a cause of action arising under the Civil Rights Act of 1964

for race and sex discrimination, for a cause of action of age discrimination arising under the Age

Discrimination in Employment Act ("ADEA"), 29 U.S.C. § 621, et seq., and a cause of action under

42 U.S.C. § 1981, to address claims of race discrimination.

4.

Defendant hired Plaintiff as a female news reporter/anchor in 1999. On October 4, 2021,

Plaintiff signed a formal employment agreement. See News Personnel Employment Agreement,

attached hereto as Exhibit “A.” Thereafter, Plaintiff worked successfully in various capacities until

October 2022.

5.

On October 28, 2022, Plaintiff used the word “grandmammie” in an exchange with a

coworker. Defendant pointed out to Plaintiff that the word “grandmammie” could have a racial

connotation. Plaintiff did not believe the word “grandmammie” had a racial connotation but,

nevertheless, apologized for using the term. Defendant, however, was apparently anxious to be rid

of Plaintiff and gave Plaintiff a disciplinary notice because she used the term. See Disciplinary

Notice, attached hereto as Exhibit “B.”

6.

On March 8, 2023, Plaintiff was talking with a male news person about a popular personality,

Snoop Dogg, and made the statement “fo shizzle, my nizzle.” Defendant claimed that this comment

was inappropriate.

-2-
Case 3:23-cv-03154-DPJ-ASH Document 1 Filed 12/13/23 Page 3 of 6

7.

On March 14, 2023, Defendant terminated Plaintiff’s employment.

8.

Plaintiff is a white female and is fifty-one (51) years old. Plaintiff was replaced by an

African-American female in her early thirties.

9.

Plaintiff believes the television market in which she worked is primarily African-American.

It is likely that Defendant regards being African-American and being young as desirable job

requirements, and it is likely Defendant regards being older (fifty-one (51)) and white as job

detriments.

10.

Plaintiff has filed an EEOC charge, attached hereto as Exhibit “C,” and received the right to

sue letter, attached hereto as Exhibit “D.” The allegations in the EEOC charge are incorporated

herein by reference.

11.

Plaintiff was discharged based upon her race in violation of the Civil Rights Act of 1964, 42

U.S.C. § 2000, et seq., and in violation of 42 U.S.C. § 1981.

12.

Plaintiff was discharged because she was an older female in violation of the Age

Discrimination in Employment Act and in violation of Title VII of the Civil Rights Act of 1964.

-3-
Case 3:23-cv-03154-DPJ-ASH Document 1 Filed 12/13/23 Page 4 of 6

13.

Plaintiff has suffered mental anxiety and stress and lost income as a result of Defendant’s

actions. Additionally, Defendant’s discharging Plaintiff is outrageous, such that punitive damages

are due. Any discrimination based upon age was willful since the Age Discrimination in

Employment Act is well known to Defendant.

14.

Defendant’s treatment of Plaintiff is especially outrageous because it required her to execute

an unreasonable noncompete agreement, which substantially hinders her finding employment in her

chosen career.

15.

This noncompete agreement is unenforceable because Plaintiff’s discharge was without

cause. Defendant’s attempt to enforce the noncompete is another outrageous act by Defendant.

Plaintiff asks this Court to declare the noncompete agreement void.

REQUEST FOR RELIEF

Plaintiff requests actual, punitive, and liquidated damages in an amount to be determined by

a jury, reinstatement, and reasonable attorneys’ fees and costs. Plaintiff also requests that the

noncompete agreement be declared void.

-4-
Case 3:23-cv-03154-DPJ-ASH Document 1 Filed 12/13/23 Page 5 of 6

RESPECTFULLY SUBMITTED, this the 13th day of December, 2023.

BARBIE BASSETT, Plaintiff

By: /s/ JIM WAIDE


Jim Waide, MS Bar No. 6857
[email protected]
Rachel Waide Pierce, MS Bar No. 100420
[email protected]
WAIDE & ASSOCIATES, P.A.
332 North Spring Street
Tupelo, MS 38804-3955
Post Office Box 1357
Tupelo, MS 38802-1357
(662) 842-7324 / Telephone
(662) 842-8056 / Facsimile

ATTORNEYS FOR PLAINTIFF

-5-
Case 3:23-cv-03154-DPJ-ASH Document 1 Filed 12/13/23 Page 6 of 6

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