Intentional Discrimination & Retaliation Case

August 8, 2006

On August 8, 2006, the Bernabei Law Firm, along with the Lawyers' Committee for Civil Rights Under Law and local counsel Dale E. Williams filed a civil action in the United States District Court for the Western District of Louisiana, Lake Charles Division, against a U.S. Department of Defense contractor and its subcontractor, for intentional discrimination and retaliation in violation of Section 1981 of the Civil Rights Act of 1866 and Title VII of the Civil Rights Act of 1964.

The complaint alleges that Ms. Susan Safi-Rafiq, and others similarly situated, were subjected to a dangerous, humiliating and hostile work environment because of their race, sex and national origin while jointly employed by the contractors. In July 2004, Ms. Safi-Rafiq, who fled her native country of Afghanistan in 1980, was hired to serve as a role-player in simulations designed to replicate life in her native country for U.S. soldiers training for their mission in Afghanistan. She and a dozen other women, many of whom had limited English proficiency, were bused to Ft. Polk, Louisiana, the site of the simulations. Upon arriving at Ft. Polk the women were escorted to the barracks where they had to sleep, but which were not suitable for human habitation. According to the complaint, the floors, walls and bathroom were filthy, the room was infested with vermin, and there was almost no ventilation in the single room where all of the women were forced to sleep. The women were also subjected to taunts, insults and harassment specifically directed at their race and sex. For example, when Ms. Safi-Rafiq requested a fan from one of her managers he told her that she should keep her mouth shut and that if the women did not speak English they did not deserve better. He then grabbed her by the arm, pushed her and threatened, "You know what we did to women like you in Bosnia." Ms. Safi-Rafiq reported the assault and verbal threat as well as the dangerous conditions within the barracks, however, no action was taken by the contractors and she was retaliated against because of her complaints.