Maryland State Civil Rights Complaint

CIVIL RIGHTS COMPLAINT — MARYLAND STATE LAW (MFEPA / SUBTITLES 3, 6, 7)

TABLE OF CONTENTS

1. Caption
2. Introduction
3. Parties
4. Jurisdiction and Venue
5. Administrative Exhaustion
6. Factual Allegations
7. Count I — Discrimination Under Md. State Gov't § 20-606 (Employment)
8. Count II — Hostile Work Environment / Harassment Under § 20-606
9. Count III — Retaliation Under § 20-606(f)
10. Count IV — Public Accommodations Discrimination Under § 20-304 (Alternative)
11. Count V — Housing Discrimination Under § 20-705 (Alternative)
12. Count VI — Parallel Federal Counts (Title VII / ADA / ADEA / FHA)
13. Damages
14. Prayer for Relief
15. Demand for Trial by Jury
16. Signature and Service Blocks
17. Certificate of Service
18. Maryland Practice Notes
19. Sources and References

1. CAPTION

IN THE CIRCUIT COURT FOR [________________________________] COUNTY, MARYLAND

CIVIL ACTION NO. [________________________________]

COMPLAINT AND DEMAND FOR JURY TRIAL

2. INTRODUCTION

Plaintiff [PLAINTIFF NAME] ("Plaintiff"), by and through undersigned counsel, brings this civil rights action against Defendants for discriminatory conduct in violation of the Maryland Fair Employment Practices Act, Md. Code Ann., State Gov't §§ 20-601 et seq.; Maryland's prohibition on discrimination in places of public accommodation, Md. Code Ann., State Gov't §§ 20-301 et seq.; Maryland's fair-housing laws, Md. Code Ann., State Gov't §§ 20-701 et seq.; and the parallel federal civil rights statutes identified below. Plaintiff seeks declaratory, injunctive, equitable, and monetary relief including back pay, front pay, compensatory damages within the statutory caps of § 20-1009, attorneys' fees and costs, and (under federal counts only) punitive damages.

3. PARTIES

3.1. Plaintiff [NAME] is an adult individual residing at [ADDRESS] in [COUNTY] County, Maryland. At all relevant times, Plaintiff was a member of one or more classes protected by Md. State Gov't §§ 20-606, 20-304, and/or 20-705, specifically: [PROTECTED CHARACTERISTIC(S) — e.g., race (African American), sex (female), sexual orientation (lesbian), gender identity (transgender), disability ([DESCRIBE]), national origin ([COUNTRY]), age (over 40), religion ([RELIGION]), marital status, military status].

3.2. Defendant [EMPLOYER / OPERATOR / HOUSING PROVIDER] ("Defendant [SHORT NAME]") is a [corporation / LLC / partnership / sole proprietorship] organized under the laws of [STATE], with its principal place of business at [ADDRESS]. Defendant is an "employer" within the meaning of Md. State Gov't § 20-601(d) because it has fifteen (15) or more employees for each working day in each of twenty (20) or more calendar weeks in the current or preceding calendar year, and/or qualifies as a place of public accommodation under § 20-301 or a housing provider under § 20-701.

3.3. [Optional: Individual Defendant.] Defendant [NAME] is an adult individual who, at all relevant times, served as Plaintiff's [supervisor / manager / owner] and is sued in his/her individual capacity to the extent permitted by Md. State Gov't § 20-606(a)(5) (aiding and abetting) and applicable federal law.

4. JURISDICTION AND VENUE

4.1. This Court has subject-matter jurisdiction over the Maryland statutory claims pursuant to Md. Code Ann., Cts. & Jud. Proc. § 1-501 (general circuit court jurisdiction) and Md. State Gov't § 20-1013 (express right to civil action).

4.2. [If federal forum:] This Court has federal-question jurisdiction over Counts under Title VII, the ADA, the ADEA, and the FHA pursuant to 28 U.S.C. § 1331, and supplemental jurisdiction over the Maryland statutory claims pursuant to 28 U.S.C. § 1367(a).

4.3. Venue is proper in [COUNTY] County under Md. Code Ann., Cts. & Jud. Proc. § 6-201 because Defendant [carries on a regular business / resides / was served] here, and/or under § 6-202 because the cause of action arose in this county.

4.4. The amount in controversy exceeds [$30,000 / $75,000], exclusive of interest and costs.

5. ADMINISTRATIVE EXHAUSTION

5.1. On [DATE], Plaintiff timely filed a Charge of Discrimination with the Maryland Commission on Civil Rights ("MCCR"), Charge No. [________________________________], alleging the conduct described herein. The Charge was filed within three hundred (300) days of the unlawful employment practice as required by Md. State Gov't § 20-1004(c)(2) (or within two (2) years for harassment under § 20-1004(c)(3), or within six (6) months for non-employment discrimination under § 20-1004(c)(1)).

5.2. The MCCR Charge was cross-filed with the U.S. Equal Employment Opportunity Commission ("EEOC") pursuant to the work-sharing agreement between MCCR and EEOC, EEOC Charge No. [________________________________].

5.3. More than one hundred eighty (180) days have elapsed since the filing of the administrative charge, satisfying the prerequisite of Md. State Gov't § 20-1013(a)(2). [OR: On (DATE), the EEOC issued a Notice of Right to Sue, and this Complaint is filed within ninety (90) days of receipt thereof.]

5.4. This Complaint is timely filed within two (2) years of the alleged unlawful employment practice (three (3) years for harassment) as required by Md. State Gov't § 20-1013(a)(3); the limitations period was tolled during the pendency of the administrative charge.

6. FACTUAL ALLEGATIONS

6.1. Plaintiff was hired by Defendant on [DATE] as a [POSITION TITLE] at a salary of [$AMOUNT] per [year/hour].

6.2. Throughout Plaintiff's employment, Plaintiff performed [his/her/their] job duties competently, met or exceeded all legitimate performance expectations, and received [describe positive reviews, raises, promotions, awards].

6.3. Beginning on or about [DATE], Plaintiff was subjected to the following adverse and discriminatory conduct because of [PROTECTED CHARACTERISTIC]:

• [DESCRIBE INCIDENT 1 — date, actor, location, conduct, witnesses];
• [DESCRIBE INCIDENT 2];
• [DESCRIBE INCIDENT 3];
• [Continue with chronological narrative.]

6.4. [Comparators / Pretext.] Similarly situated employees outside Plaintiff's protected class were treated more favorably, including: [NAME COMPARATORS, describe their treatment]. The reason given by Defendant for [adverse action], namely [STATED REASON], was false and pretextual because [FACTS SHOWING PRETEXT].

6.5. [Notice / Complaints.] On [DATE], Plaintiff complained internally to [HR / SUPERVISOR / NAME] about the discriminatory conduct. Defendant [failed to investigate / failed to remediate / retaliated against Plaintiff].

6.6. [Adverse action.] On [DATE], Defendant [terminated / demoted / failed to promote / suspended / refused to accommodate / refused service / refused to rent] Plaintiff. The decision-maker was [NAME, TITLE].

6.7. As a direct and proximate result of Defendant's conduct, Plaintiff has suffered lost wages and benefits, loss of career advancement, emotional distress, mental anguish, humiliation, loss of enjoyment of life, and other economic and non-economic harm.

7. COUNT I — DISCRIMINATION UNDER MD. STATE GOV'T § 20-606 (EMPLOYMENT)

7.1. Plaintiff realleges and incorporates Paragraphs 3.1 through 6.7.

7.2. At all relevant times, Defendant was an "employer" within the meaning of Md. State Gov't § 20-601(d).

7.3. Plaintiff is a member of a protected class under § 20-606 — specifically, [PROTECTED CHARACTERISTIC]. Maryland's protected classes include race, color, religion, ancestry or national origin, sex, age, marital status, sexual orientation, gender identity, genetic information, disability unrelated to the individual's ability to perform the duties of the particular employment, and military status.

7.4. Plaintiff was qualified for [his/her/their] position and was performing the job satisfactorily.

7.5. Defendant subjected Plaintiff to an adverse employment action by [DESCRIBE], in violation of Md. State Gov't § 20-606(a)(1).

7.6. The adverse action occurred under circumstances giving rise to an inference of unlawful discrimination, including the differential treatment of comparators, discriminatory remarks, deviations from policy, and the pretextual reason offered by Defendant.

7.7. Defendant's conduct was intentional, malicious, and/or undertaken with reckless indifference to Plaintiff's federally and state-protected civil rights.

8. COUNT II — HOSTILE WORK ENVIRONMENT / HARASSMENT UNDER § 20-606

8.1. Plaintiff realleges and incorporates Paragraphs 3.1 through 7.7.

8.2. Plaintiff was subjected to unwelcome harassment based on [PROTECTED CHARACTERISTIC] that was sufficiently severe or pervasive to alter the terms and conditions of Plaintiff's employment and create an abusive working environment.

8.3. Under Md. State Gov't § 20-601(j) and the 2022 amendments, the standard for harassment is whether a reasonable victim of discrimination would consider the conduct to be more than a petty slight, trivial inconvenience, or minor annoyance.

8.4. The harassment was committed by [supervisor with tangible employment authority / coworker(s) / non-employee under Defendant's control], and Defendant knew or should have known of the harassment and failed to take prompt and effective remedial action.

8.5. As a result, Plaintiff suffered the damages alleged herein.

9. COUNT III — RETALIATION UNDER § 20-606(f)

9.1. Plaintiff realleges and incorporates Paragraphs 3.1 through 8.5.

9.2. Plaintiff engaged in protected activity under Md. State Gov't § 20-606(f) by [opposing a discriminatory practice / complaining internally / filing an MCCR or EEOC charge / participating in an investigation] on [DATE].

9.3. Defendant was aware of Plaintiff's protected activity.

9.4. Within a temporal proximity supporting an inference of causation, Defendant subjected Plaintiff to materially adverse action by [DESCRIBE].

9.5. There exists a causal connection between Plaintiff's protected activity and the adverse action.

10. COUNT IV — PUBLIC ACCOMMODATIONS DISCRIMINATION UNDER § 20-304 (ALTERNATIVE)

10.1. Plaintiff realleges and incorporates Paragraphs 3.1 through 6.7.

10.2. Defendant [NAME] is a "place of public accommodation" within the meaning of Md. State Gov't § 20-301, namely a [hotel/restaurant/theater/retail establishment].

10.3. Defendant, through its [owner / agent / employee], refused, withheld from, or denied to Plaintiff the accommodations, advantages, facilities, or privileges of the place of public accommodation because of Plaintiff's [race / sex / age / color / creed / national origin / marital status / sexual orientation / gender identity / disability], in violation of Md. State Gov't § 20-304.

11. COUNT V — HOUSING DISCRIMINATION UNDER § 20-705 (ALTERNATIVE)

11.1. Plaintiff realleges and incorporates Paragraphs 3.1 through 6.7.

11.2. Defendant is a "person" engaged in the sale or rental of "dwellings" within the meaning of Md. State Gov't §§ 20-701 and 20-705, and the dwelling at issue is not exempt under § 20-706.

11.3. Defendant refused to [sell / rent / negotiate for the sale or rental of / make available] a dwelling to Plaintiff, or otherwise made the dwelling unavailable, or imposed different terms, conditions, or privileges, because of Plaintiff's [race / color / religion / sex / familial status / national origin / marital status / sexual orientation / gender identity / disability / source of income], in violation of Md. State Gov't § 20-705.

12. COUNT VI — PARALLEL FEDERAL COUNTS (TITLE VII / ADA / ADEA / FHA)

12.1. Plaintiff realleges and incorporates Paragraphs 3.1 through 11.3.

12.2. Title VII (42 U.S.C. § 2000e-2): Defendant's conduct constitutes intentional discrimination on the basis of [race / color / religion / sex (including pregnancy, sexual orientation, and gender identity per Bostock v. Clayton County, 590 U.S. 644 (2020)) / national origin] in violation of Title VII of the Civil Rights Act of 1964.

12.3. ADA (42 U.S.C. §§ 12112, 12203): Defendant's conduct constitutes disability discrimination, failure to accommodate, and/or retaliation in violation of the Americans with Disabilities Act, as amended.

12.4. ADEA (29 U.S.C. § 623): Defendant's conduct constitutes age discrimination against a person age 40 or older in violation of the Age Discrimination in Employment Act.

12.5. FHA (42 U.S.C. §§ 3604, 3617): Defendant's conduct constitutes a discriminatory housing practice in violation of the Fair Housing Act.

12.6. Plaintiff has satisfied all administrative prerequisites under each federal statute, including timely filing with the EEOC/HUD and receipt of, or eligibility for, a Notice of Right to Sue.

12.7. Under the federal counts, Plaintiff seeks compensatory damages and, where authorized, punitive damages subject to the caps of 42 U.S.C. § 1981a, plus attorneys' fees and costs under 42 U.S.C. §§ 2000e-5(k), 12205, and 3613(c)(2).

13. DAMAGES

13.1. Economic damages: back pay (lost wages, salary, bonuses, commissions, benefits, and pension contributions) from [DATE OF ADVERSE ACTION] through the date of judgment; front pay or, in the alternative, reinstatement; lost future earning capacity; and out-of-pocket expenses, in an amount to be proven at trial.

13.2. Compensatory damages — state counts: for emotional pain, suffering, inconvenience, mental anguish, loss of enjoyment of life, and other nonpecuniary losses, subject to the caps in Md. State Gov't § 20-1009(e):

13.3. Compensatory and punitive damages — federal counts: within the combined caps of 42 U.S.C. § 1981a(b)(3), tiered by employer size from $50,000 (15-100 employees) up to $300,000 (501+ employees) for compensatory plus punitive combined.

13.4. Equitable relief: declaratory judgment, injunctive relief, reinstatement, restoration of seniority and benefits, expungement of adverse personnel records, and a court-ordered training and policy-revision program.

13.5. Attorneys' fees and costs: under Md. State Gov't § 20-1015 (where applicable), 42 U.S.C. § 2000e-5(k), 42 U.S.C. § 12205, 42 U.S.C. § 3613(c)(2), and 42 U.S.C. § 1988.

13.6. Pre- and post-judgment interest at the legal rate.

14. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully demands that this Court:

• A. Enter judgment for Plaintiff and against Defendants on each Count;
• B. Award back pay, front pay, and lost benefits;
• C. Award compensatory damages within the caps of Md. State Gov't § 20-1009 and 42 U.S.C. § 1981a(b)(3);
• D. Award punitive damages under the federal counts in an amount sufficient to punish and deter;
• E. Order Defendants to reinstate Plaintiff (or, in the alternative, award front pay), restore seniority and benefits, and expunge all adverse personnel records;
• F. Issue declaratory and injunctive relief barring Defendants from further violations and requiring training and policy reform;
• G. Award reasonable attorneys' fees, expert fees, and costs;
• H. Award pre- and post-judgment interest; and
• I. Grant such other and further relief as the Court deems just and proper.

15. DEMAND FOR TRIAL BY JURY

Plaintiff hereby demands a trial by jury on all issues so triable as a matter of right under Md. R. Civ. P. 2-325, the Maryland Declaration of Rights Article 23, and Federal Rule of Civil Procedure 38.

16. SIGNATURE AND SERVICE BLOCKS

Date: [__/__/____]

Respectfully submitted,

[LAW FIRM NAME]

By: [________________________________]

[ATTORNEY NAME]

Maryland AIS / Bar No. [________________________________]

[STREET ADDRESS]

[CITY, MD ZIP]

Telephone: [(___) ___-____]

Email: [________________________________]

Counsel for Plaintiff

17. CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this [____] day of [_______________], 20[____], a copy of the foregoing COMPLAINT AND DEMAND FOR JURY TRIAL was served upon the following by [hand delivery / first-class mail / certified mail, return receipt requested / MDEC electronic service]:

[DEFENDANT'S RESIDENT AGENT / COUNSEL OF RECORD]

[ADDRESS]

[________________________________]

[ATTORNEY NAME]

18. MARYLAND PRACTICE NOTES

• Pleading standard. Maryland is a fact-pleading jurisdiction under Md. R. Civ. P. 2-305, requiring "a clear statement of the facts necessary to constitute a cause of action." Conclusory allegations are insufficient. Bobo v. State, 346 Md. 706 (1997). Plead specific dates, actors, and conduct under each count.
• MFEPA broader than Title VII. Maryland's protected classes under § 20-606 are broader than Title VII and include sexual orientation, gender identity, marital status, military status, and genetic information. The 2022 amendments lowered the harassment threshold to conduct that "a reasonable victim" would consider more than a petty slight or trivial inconvenience — a more plaintiff-friendly standard than the federal "severe or pervasive" test.
• Damages caps mirror Title VII structure but exclude punitives. Section 20-1009 caps compensatory damages by employer size ($50K / $100K / $200K / $300K) but does NOT authorize punitive damages. Always plead a parallel Title VII count if punitive damages are sought.
• 180-day exhaustion + 2-year SOL. Under § 20-1013, a complainant must file an MCCR/EEOC/local charge first, wait 180 days, and bring the civil action within 2 years (3 years for harassment) of the unlawful practice. The limitations period is tolled while the charge is pending.
• Local enforcement agencies. Howard, Montgomery, Prince George's, Baltimore City, Baltimore County, and Anne Arundel County operate certified local human-relations agencies that may receive charges in lieu of MCCR. The 300-day filing deadline applies under § 20-1004(c)(2). Verify deferral status before filing.
• Individual liability. Maryland recognizes individual liability for aiders and abettors under § 20-606(a)(5); Title VII does not. Consider naming individual decision-makers under the state count.
• Removal risk. Maryland complaints with federal counts are removable to the District of Maryland under 28 U.S.C. § 1441. If you intend to remain in state court, plead state-only counts and waive any federal claims, or stipulate that damages do not exceed federal removal thresholds where applicable.
• Forum. Md. State Gov't § 20-1013 authorizes the civil action in "a court of competent jurisdiction." Circuit court is the standard forum; District Court is available only where the amount in controversy is below $30,000 and the case does not seek injunctive relief.
• Attorneys' fees. Recoverable under § 20-1015, 42 U.S.C. § 2000e-5(k), § 12205, § 3613(c)(2), and § 1988. Document hours contemporaneously.
• Settlement / mediation. MCCR offers voluntary mediation under § 20-1005. If the parties reach a conciliation agreement during the administrative process, it may be enforced under § 20-1006.

19. SOURCES AND REFERENCES

• Md. Code Ann., State Gov't § 20-606 — Unlawful Employment Practices — https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gsg&section=20-606
• Md. Code Ann., State Gov't § 20-304 — Public Accommodations Prohibited Act — https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gsg&section=20-304
• Md. Code Ann., State Gov't § 20-705 — Discriminatory Housing Practices — https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gsg&section=20-705
• Md. Code Ann., State Gov't § 20-1004 — Filing of Complaint / Time Limits — https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gsg&section=20-1004
• Md. Code Ann., State Gov't § 20-1009 — ALJ Remedies and Compensatory Caps — https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gsg&section=20-1009
• Md. Code Ann., State Gov't § 20-1013 — Civil Action by Complainant — https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gsg&section=20-1013
• Maryland Commission on Civil Rights — https://mccr.maryland.gov/
• MCCR Time Limits Guidance — https://mccr.maryland.gov/Pages/a-Time-Limits.aspx
• MCCR Employment Discrimination — https://mccr.maryland.gov/Pages/Employment-Discrimination.aspx
• Maryland Rules of Civil Procedure (Title 2) — https://mdcourts.gov/rules
• 42 U.S.C. § 2000e et seq. (Title VII)
• 42 U.S.C. § 12101 et seq. (ADA)
• 29 U.S.C. § 621 et seq. (ADEA)
• 42 U.S.C. § 3601 et seq. (FHA)
• 42 U.S.C. § 1981a (Federal damages caps)
• Bostock v. Clayton County, 590 U.S. 644 (2020) (sexual orientation / gender identity as sex)
• Haas v. Lockheed Martin Corp., 396 Md. 469 (2007) (MFEPA construction)

Disclaimer: This template is provided for informational purposes only and does not constitute legal advice. An attorney licensed in Maryland must review and customize this document before filing. Laws, citations, and court rules change frequently; verify all authorities before use.