A former counselor for Randolph-Macon Academy claims the school fired her in 2016 after she complained of sexual discrimination by officials and overtime violations.

Jumanah Khader claims in a complaint filed in U.S. District Court in Harrisonburg  that Randolph-Macon Academy violated her civil rights, the Federal Fair Labor Standards Act and Virginia law. Alexandria attorney Monique A. Miles filed the complaint  on Wednesday on Khader’s behalf.

Khader seeks declaratory, injunctive and monetary relief for harm she claims to have suffered as a result of sex discrimination and retaliation by the school; overtime pay violations and retaliation for reporting these to school management. Khader, who lives in Front Royal, also seeks relief from the school for breaching her employment contract by terminating her before the agreement expired.

Khader has asked for a jury trial.

Miles said Thursday she advised school officials of the complaint prior to filing the lawsuit. Online court records show an electronic summons dated Thursday was sent to the academy.

R-MA Director of Communications Celeste M. Brooks stated in an email Friday seeking a response to the complaint that “it is the Academy’s policy not to comment on pending litigation. All I can tell you is that we believe the claims to be unfounded, and we intend to defend the Academy vigorously.”

Khader worked as a Cadet Life Supervisor at R-MA’s upper school from Aug. 23, 1999 until her termination in June 2016. The complaint states Khader worked as an exemplary employee who received outstanding performance reviews and multiple awards from the school.

Khader contacted the Equal Employment Opportunity Commission’s Washington Field Office on Dec. 27, 2016 regarding discrimination at R-MA and filed a charge of discrimination within 180 days after one or more alleged unlawful practices in violation of Title VII occurred. The plaintiff received a notice of the right to sue from the Equal Employment Opportunity Commission dated May 14, 2018. The notice gave Khader 90 days to file her complaint on or before Wednesday.

“Given her success and achievement at R-MA, Ms. Khader believes that but for her gender and the (Fair Labor Standards Act) wage violations she reported she would not have been terminated,” the complaint states.

The R-MA website as of Thursday featured Khader, a graduate of the class of 1996, in a  “Who’s Who” piece that included a video.

Khader claims in her complaint that the school failed to pay her overtime, as she averaged 55 hours a week, sometimes exceeding 60 hours. However, the school did not keep or maintain accurate and reliable records of her hours. The defendant knowingly violated the plaintiff’s federal overtime compensation rights and, as such, the school owes her unpaid wages for the time worked in excess of 40 hours per week, the complaint states.

Khader also claims she endured sexual discrimination at the school, stating in the complaint that an administrator “had discriminatory and unreasonable expectations for female” cadet life supervisors.

“R-MA applied more preferential rules to male CLSs … R-MA paid overnight staff to stay awake during the overnight hours to provide coverage for both male and female CLSs, but they still required the female CLSs to remain on campus despite having coverage and despite the male CLSs being allowed to go off campus at night,” the complaint states. “For years, the female CLSs were required to be on-call throughout the night in addition to their regular duty, whereas the male CLSs were permitted to go off campus to casinos, bars, and their friends’ homes. The male CLS could be out all night and sometimes did not return until the next day.”

Khader’s complaint outlines other examples of alleged sexual discrimination against female staff members, such as applying certain rules pertaining to sick leave, second jobs, perks and professional development training to female workers that differed from those required or offered to male employees.

Khader advised Director of Human Resources Krista Peacock and other administrators during the summer of 2015 about the treatment of female employees. Khader voiced her concerns to R-MA President David C. Wesley via email June 1, 2015. She attached a spreadsheet explaining the additional hours her supervisors demanded, on top of overtime she worked without compensation. Wesley met with human resources and Price but provided no remedy to address Khader’s overtime complaints.

Overtime violations continued into 2016 and Khader raised the issue with supervisors through the winter. On April 11, 2016, Khader noticed on her Google calendar that several supervisors were conducting interviews with prospective women for her position and that of a co-worker also identified in the lawsuit as aggrieved.

R-MA officials did not acknowledge between June 1, 2015 and June 12, 2016 Khader’s complaints about gender discrimination, scheduling or overtime pay or take steps to investigate matters or resolve them, the lawsuit states.

Khader claims she suffered retaliation by the school administration whenever she raised her concerns. Wesley notified Khader via letter on April 26, 2016, that the school would not renew her contract and would terminate her employment effective June 12, 2016, the plaintiff states. Khader also claims that R-MA’s notification breached her contract, which did not expire until after the 2016 summer school session on July 21, 2016. The plaintiff states R-MA owes her wages from June 12, 2016 to July 31, 2016 as a result of the breach.

Khader claims work-related stress took a toll on her physical health as well as her emotional and psychological well-being.

Khader claims the school subjected her to discriminatory gender bias in violation of the Civil Rights Act of 1964, and to different terms and conditions of employment because of her sex. As a result, the plaintiff claims she suffered a loss in wages and benefits, diminished future earning capacity, emotional pain and suffering, inconvenience, mental anguish, loss of enjoyment of life, and other pecuniary and non-pecuniary losses.