IN THE UNITED STATES DISTRICT COURT FOR THE
MIDDLE DISTRICT OF TENNESSEE
NORTHEASTERN DIVISION

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KEVIN BROWN No. 2:14-cv-00011

Plaintiff, Judge Sharp

AMENDED COMPLAINT
V.
JURY DEMAND
MISTER WAYNE'S SCHOOL OF
UNISEX HAIR DESIGN

Defendant.

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PLAINTIFF'S FIRST AMENDED COMPLAINT

I. INTRODUCTION 1. This cause of action arises from the Defendant's deliberately indifferent response to reports of student-on-student harassment based on the Plaintiff's perceived gender-stereotype, and subsequent sex-based discrimination by employees. The Plaintiff was targeted by students and employees of the Defendant because he did not conform to stereotypical expectations of masculinity. The personality traits that the Plaintiff exhibited were considered to be feminine, and triggered an animus in many students, employees, even administrators, because they believed him to be gay. Indeed, even the appearance of homosexuality is enough to ignite a fire of prejudice and hatred among some of the -1- students, employees, and administrators of the Defendant. Employee Bridgette Wilson, publicly demonstrates her enmity against gays by posting images of the anti-gay activist, Phil Robertson, who claims that homosexuals are “going to hell”, onto the popular social networking site, Facebook. Another student, Sara, also proudly proclaims her animus of, even the appearance that someone is gay, by mockingly posting a photo on Facebook of her husband dressed as Phil Robertson ,while holding her in his arms. Other students display postings of repulsive objects such as, a rebel flag, skull and cross bones, “redneck”, “southern pride”, and “I agree with Phil”. The majority of them live many