Kentucky Firefighter-Medic Files Suit Against Second Fire Department

A firefighter who is already suing one Louisville Metro fire department for gender discrimination, sexual harassment, and retaliation has filed suit against a second fire department for refusing to honor its offer to hire her. Jamie Keith filed suit today in US District Court for the Western District of Kentucky against the Okolona Fire Protection District contending its refusal to hire her as a PRN paramedic constituted sex discrimination and retaliation.

Keith filed suit in 2021 against the Pleasure Ridge Park Fire Department alleging sexual harassment, retaliation, disability discrimination and FMLA violations. Here is a link to my earlier coverage of that lawsuit.

In her suit against Okolona, she claims she applied and was hired as a PRN paramedic (PRN referring to the Latin term “pro re nata” which translates to “as needed”). Quoting from the complaint:

  • At the time of her hiring, Plaintiff was employed by Pleasure Ridge Park and Fire Department. Her employment with PRPFD required her to regularly attend a training program.
  • As a result of the training program, Plaintiff was unable to attend Defendant’s orientation in May 2020.
  • At that time, Defendant did not indicate to Plaintiff that missing the orientation would be an issue. On the contrary, Defendant encouraged Plaintiff to complete the PRPFD training program.
  • Furthermore, Plaintiff made multiple attempts to reschedule her orientation with Defendant.
  • On or around June 15, 2020, Plaintiff contacted Assistant Chief Director, Tom Puckett, to confirm that she was still employed by Defendant. In response, Mr. Puckett said, “I don’t know, are you?” Mr. Puckett then went on to say that there were no available upcoming orientation dates. Mr. Puckett did not respond to any additional inquiries from Plaintiff.
  • On or around December 8, 2020, Plaintiff contacted Chief Mark Little to complain about the lack of transparency and responsiveness she was experiencing with Mr. Puckett. Plaintiff also sought confirmation regarding her employment with Defendant. Plaintiff received no response.
  • On or around December 9, 2020, Mr. Puckett posted on Facebook that Defendant had hired a new full-time EMT.
  • The new EMT completed the orientation program while Plaintiff was not given an opportunity to do so.
  • Around this time, Josh Johnson, who was employed by both Defendant and PRPFD as a supervisor, informed Defendant of the escalating nature of Plaintiff’s complaints of discrimination based on sex and sexual harassment while employed by PRPFD.
  • In late December 2020 or early January 2021, Plaintiff applied for a Fire Fighter position with Defendant.
  • On or around January 26, 2021, Plaintiff emailed Mr. Puckett and requested an update on her PRN position as well as to complete her orientation.
  • That same day, Plaintiff received an email from Defendant stating that because she failed to complete orientation, she was required to resign or else she would be subject to disciplinary charges. As a result, on January 29, 2021, Plaintiff was constructively discharged from her position with Defendant.

The complaint alleges gender discrimination and retaliation under state and federal law. Here is a copy of the complaint:

About Curt Varone

Curt Varone has over 45 years of fire service experience and 35 as a practicing attorney licensed in both Rhode Island and Maine. His background includes 29 years as a career firefighter in Providence (retiring as a Deputy Assistant Chief), as well as volunteer and paid on call experience. He is the author of two books: Legal Considerations for Fire and Emergency Services, (2006, 2nd ed. 2011, 3rd ed. 2014, 4th ed. 2022) and Fire Officer's Legal Handbook (2007), and is a contributing editor for Firehouse Magazine writing the Fire Law column.

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