Justice Department Settles Sexual Harassment and Retaliation Lawsuit for Two Female Firefighters; Changes Houston Fire Department’s Training Practices

The Justice Department announced on Monday, October 26, 2020 that it has reached a settlement with the City of Houston resolving allegations that personnel at Houston Fire Department (HFD) Station 54 discriminated and retaliated against former firefighter Jane Draycott in violation of Title VII of the Civil Rights Act of 1964. Title VII is a federal statute that prohibits employment discrimination on the basis of race, color, national origin, sex and religion.

The department also announced the April 28, 2020 settlement of the Title VII claims brought in its lawsuit on behalf of Houston firefighter Paula Keyes. Once the resolution announced today involving Draycott’s claims is entered by the court, all Title VII claims brought by the United States in its lawsuit will be resolved.




“There is no place in the workplace for the type of egregious sexual harassment that these two female Houston firefighters suffered in this case, and the retaliation one firefighter endured after she complained is intolerable and unlawful. Sexual harassment and retaliation of this kind artificially slam shut the doors of equal employment opportunity for women who work in jobs historically dominated by men,” said Assistant Attorney General Eric S. Dreiband. “These two strong women and anyone else who is hardworking and courageous enough to serve as a first responder deserve the full protection of the Civil Rights Act. The Department of Justice is and will remain dedicated to enforcing these protections so that firefighters and other public safety officials can protect and serve the public free from illegal sex discrimination.”

“This settlement agreement exemplifies our commitment to civil rights and sends a clear message that the U.S. Attorney’s Office will continue to protect all Americans, including public sector employees, from unlawful discrimination, retaliation and sexual harassment in the workplace,” said U.S. Attorney Ryan K. Patrick for the Southern District of Texas. “The type of systematic discrimination suffered by HFD female firefighters can only be prevented when employers unequivocally promote a workplace free from discrimination.”

Draycott and Keyes each filed charges of discrimination with the Equal Employment Opportunity Commission (EEOC). The EEOC’s Houston Office investigated the charges and made reasonable cause findings. After unsuccessful conciliation efforts, the EEOC referred the charges to the Justice Department.




According to the department’s complaint, filed in the Southern District of Texas, female firefighters Jane Draycott and Paula Keyes were subjected to a hostile work environment based on sex when they were employed at the HFD’s Station 54, located at Bush Intercontinental Airport in north Houston. The complaint alleged that, during the time that both Draycott and Keyes worked at Station 54, they were subjected to the soiling of their bathroom by male co-workers who urinated against the walls, floors, and sinks of that space. That misconduct escalated over time to dangerous activities that jeopardized the personal safety of Keyes and Draycott and their ability to do their jobs, to include the disconnection of the cold water in their showers and the silencing of the public announcement speakers in their residential areas such that they could not respond to emergency fire calls. This conduct was persistent even though Draycott complained about it through her chain of command. Prior to Draycott’s and Keyes’ transfer to Station 54, other female firefighters who had previously worked at Station 54 made similar complaints to the HFD about the conduct. According to the complaint, the HFD did not take meaningful steps to stop the discrimination against these other women.

The complaint further alleged the harassing conduct culminated in death threats and vulgar race- and gender-based slurs written on the walls of their work and living spaces and on their personal possessions. Finally, the complaint also alleged that the HFD retaliated against Draycott for complaining about her working conditions by publicly disparaging her in a workplace meeting in order to force her to leave the station. Ultimately, Draycott left HFD’s employment earlier than anticipated due to the intolerable working conditions.

Training & Settlement

Under the terms of the Oct. 26, 2020 consent decree with the City of Houston concerning HFD’s Station 54, which is subject to court approval, the city must provide training to certain supervisory staff and provide proof of compliance for up to 12 months. The city also agreed to pay Draycott $275,000.00 to resolve the claims of sex-based harassment and retaliation stemming from her employment with the HFD. In a separate settlement agreement executed in April 2020, the city agreed to pay $67,500.00 to Keyes to resolve similar claims alleged by the United States in its complaint via a separate settlement agreement.

The Civil Rights Division’s Employment Litigation Section brought and resolved the case in collaboration with the U.S. Attorney’s Office for the Southern District of Texas. This matter was handled by Employment Litigation Section attorneys Karen Woodard, Jeremy Monteiro, Hector Ruiz, and Hillary Valderrama and Assistant United States Attorneys Keith Wyatt and Elizabeth Karpati of the Southern District of Texas.




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