Missouri Fire Department Sued for Sexual Harassment

A nurse who was hired by a Missouri fire department in April, 2022 has filed suit claiming that sexual harassment forced her to request a reduction to part-time status in September, 2022 and resign in December, 2022. Christeena Ferguson filed suit in Jackson County Circuit Court alleging three state law counts of sexual harassment and discrimination against the Southern Jackson County Fire Protection District.

The suit lists two-months’ worth of allegations of boorish behavior by a firefighter, whose name was redacted from the copy of the complaint available from the court’s web site. The conduct occurred both on-duty and off-duty in June and July, 2022. Ferguson filed a written complaint about the firefighter on August 1, 2022.  He was subsequently promoted to captain, prompting Ferguson to become concerned about having to work as his subordinate. Quoting from the complaint:

  • On or about September 6, 2022, Plaintiff resigned from full-time employment with Defendant, and changed to part-time employment, because Defendant deliberately rendered her working conditions so intolerable that she was forced to switch to part-time employment.
  • In December 2022, Plaintiff resigned her employment with Defendant as a result of Defendant deliberately rendering Plaintiff’s working conditions so intolerable that she was forced to quit her job.
  • Plaintiff’s female sex was a motivating factor in the harassing conduct she suffered.
  • The unwelcome sexual harassment was sufficiently severe or pervasive as to alter
  • the conditions of her employment and create an abusive, hostile, intimidating and offensive working environment because of her sex.
  • The harassment was subjectively intimidating and/or offensive to Plaintiff and would have been so intimidating and/or offensive to a reasonable person.
  • This unwelcome sexual harassment adversely affected Plaintiff’s terms, conditions, and privileges of her employment.
  • Defendant is vicariously liable for the conduct of [the unnamed firefighter/captain] because he was a supervisor to Plaintiff.
  • As a direct and proximate result of Defendant’s conduct described herein Plaintiff has suffered from, and is expected to continue to suffer from, degradation, pain, anguish, anxiety, and emotional distress.

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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