Colorado Civil Rights Division (CCRD) Administrative Charge

CHARGE OF DISCRIMINATION — COLORADO CIVIL RIGHTS DIVISION

Submitted to: Colorado Civil Rights Division (CCRD), 1560 Broadway, Suite 825, Denver, CO 80202 — (303) 894-2997 — ccrd.colorado.gov

Cross-Filed with: U.S. Equal Employment Opportunity Commission (EEOC) Denver Field Office under the CCRD/EEOC Worksharing Agreement

CCRD Charge No.: [________________________________]

EEOC Charge No.: [________________________________]

TABLE OF CONTENTS

1. Charging Party (Complainant) Information
2. Respondent Information
3. Statutes Invoked / Bases of Discrimination
4. Earliest and Latest Date of Discrimination
5. Statement of Particulars (Narrative)
6. Witnesses and Comparators
7. Documentary Evidence Available
8. Relief Sought
9. Verification and Signature
10. Certificate of Mailing
11. Colorado Practice Notes
12. Sources and References

1. CHARGING PARTY (COMPLAINANT) INFORMATION

2. RESPONDENT INFORMATION

3. STATUTES INVOKED / BASES OF DISCRIMINATION

I believe I have been discriminated against because of (check all that apply):

Protected classes — CADA, C.R.S. § 24-34-402 (employment), § 24-34-502 (housing), § 24-34-601 (public accommodations):

• ☐ Race
• ☐ Color
• ☐ Religion / Creed
• ☐ Sex (including pregnancy and related medical conditions)
• ☐ Sexual orientation
• ☐ Gender identity
• ☐ Gender expression
• ☐ National origin / Ancestry
• ☐ Disability (mental or physical)
• ☐ Age (40 and older; employment only under CADA)
• ☐ Marital status (added by POWR Act, SB 23-172, effective Aug. 7, 2023)
• ☐ Familial status (housing)
• ☐ Source of income (housing — C.R.S. § 24-34-502)
• ☐ Veteran or military status
• ☐ Retaliation for protected activity (C.R.S. § 24-34-402(1)(e))

Type of practice complained of:

• ☐ Failure to hire
• ☐ Discharge / termination
• ☐ Constructive discharge
• ☐ Demotion / failure to promote
• ☐ Discipline
• ☐ Compensation / wage discrimination
• ☐ Terms or conditions of employment
• ☐ Harassment / hostile environment (post-POWR Act standard — need not be "severe or pervasive")
• ☐ Failure to accommodate disability
• ☐ Failure to accommodate religion
• ☐ Pregnancy accommodation denial
• ☐ Retaliation
• ☐ Denial of housing / refusal to rent or sell
• ☐ Discriminatory housing terms or services
• ☐ Denial of public accommodation
• ☐ Other: [__________________________________________]

Cross-filed for federal investigation under (check all that apply):

• ☐ Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq.
• ☐ Americans with Disabilities Act, 42 U.S.C. § 12101 et seq.
• ☐ Age Discrimination in Employment Act, 29 U.S.C. § 621 et seq.
• ☐ Genetic Information Nondiscrimination Act, 42 U.S.C. § 2000ff
• ☐ Fair Housing Act, 42 U.S.C. § 3601 et seq.
• ☐ Section 504 of the Rehabilitation Act, 29 U.S.C. § 794
• ☐ Equal Pay Act, 29 U.S.C. § 206(d)

4. EARLIEST AND LATEST DATE OF DISCRIMINATION

5. STATEMENT OF PARTICULARS (NARRATIVE)

5.1. Background and Employment Context. I, [CHARGING PARTY NAME], am a [describe protected status — race, sex, age, disability, etc.]. I was employed by Respondent [EMPLOYER NAME] as a [POSITION TITLE] from [__/__/____] to [__/__/____] at Respondent's [LOCATION] facility.

5.2. Performance. Throughout my employment, I performed my duties competently and met or exceeded Respondent's legitimate expectations. [Cite specific reviews, commendations, metrics, or promotions.]

5.3. Specific Discriminatory Acts. Beginning on or about [__/__/____], the following discriminatory acts occurred:

• (a) [DATE] — [ACTOR]: [Describe specific act — slur, demotion, denial of accommodation, disparate discipline, etc.]
• (b) [DATE] — [ACTOR]: [Describe.]
• (c) [DATE] — [ACTOR]: [Describe.]
• (d) [DATE] — [ACTOR]: [Describe.]

5.4. Comparators. Similarly situated [employees / tenants / patrons] outside my protected class were treated more favorably. Specifically: [describe comparators by initials, job title, and date].

5.5. Notice to Respondent. On [__/__/____], I reported the discriminatory conduct to [HR / supervisor / manager NAME]. Respondent's response was [no investigation / inadequate investigation / retaliation / superficial action].

5.6. Adverse Action. On [__/__/____], Respondent [terminated / demoted / disciplined / refused to hire / refused to accommodate / evicted / refused service] me. Respondent's stated reason was [stated reason], which is pretextual because [explain — shifting reasons, absence of factual basis, comparator treatment, temporal proximity to protected activity].

5.7. POWR Act Harassment Allegations (if applicable). The conduct described above constitutes harassment under C.R.S. § 24-34-402(1.3)(a), as amended by SB 23-172 (POWR Act): the conduct was unwelcome, was directed at me because of my [protected status], and the conduct was subjectively offensive to me and objectively offensive to a reasonable individual in the same protected class. The conduct need not be "severe or pervasive" to violate CADA after August 7, 2023.

5.8. Retaliation (if applicable). I engaged in protected activity by [opposing discrimination, complaining internally, filing a prior charge, participating in an investigation] on [__/__/____]. Within [____ days/weeks] thereafter, Respondent took the materially adverse action described above.

5.9. Failure to Accommodate (if applicable). I requested a reasonable accommodation for my disability on [__/__/____], namely [describe accommodation]. Respondent [denied the request / failed to engage in the interactive process / required me to disclose more medical information than necessary]. The accommodation would not have imposed an undue hardship; in particular, [explain]. Respondent may not rely on the previously-recognized "significant impact on the job" defense, which the POWR Act eliminated.

5.10. Damages. As a direct and proximate result of Respondent's conduct, I have suffered lost wages and benefits in the approximate amount of $[__________], ongoing medical and counseling expenses, emotional distress, humiliation, and reputational harm.

6. WITNESSES AND COMPARATORS

7. DOCUMENTARY EVIDENCE AVAILABLE

The following documents are available in support of the allegations and may be requested by CCRD/EEOC during investigation:

• ☐ Offer letter, employment contract, or job description
• ☐ Performance reviews, evaluations, and commendations
• ☐ Pay records, W-2s, and benefits statements
• ☐ Personnel file (5-year retention required by POWR Act)
• ☐ Internal complaint(s) and HR correspondence
• ☐ Discriminatory emails, texts, social-media posts, or recordings
• ☐ Disciplinary write-ups, PIPs, and termination notices
• ☐ Medical documentation and accommodation requests
• ☐ Comparator data (if available)
• ☐ Witness statements
• ☐ Severance or separation agreement
• ☐ Union grievance or arbitration record
• ☐ Other: [__________________________________________]

8. RELIEF SOUGHT

Charging Party requests that the Colorado Civil Rights Division and the U.S. Equal Employment Opportunity Commission:

8.1. Investigate the allegations and issue a determination of probable cause;

8.2. Conciliate the matter with a remedy that includes, at minimum:

• ☐ Reinstatement, hire, or promotion (as applicable)
• ☐ Back pay with interest from [__/__/____] to the date of reinstatement or judgment
• ☐ Front pay in lieu of reinstatement, if reinstatement is not feasible
• ☐ Restoration of seniority, benefits, and leave accruals
• ☐ Compensatory damages for emotional distress, humiliation, and inconvenience
• ☐ Punitive damages where authorized by C.R.S. § 24-34-405(3) and 42 U.S.C. § 1981a
• ☐ Reasonable attorney fees and costs (C.R.S. § 24-34-405(2)(b))
• ☐ Posting of notice and corrective training
• ☐ Removal of adverse documents from Charging Party's personnel file
• ☐ Neutral employment reference
• ☐ Accommodation of Charging Party's disability or religion
• ☐ Other: [__________________________________________]

8.3. If conciliation fails, issue a Notice of Right to Sue under C.R.S. § 24-34-306(11), (15) so that Charging Party may pursue a civil action.

9. VERIFICATION AND SIGNATURE

I, [CHARGING PARTY NAME], declare under penalty of perjury under the laws of the State of Colorado and the United States of America that I have read the foregoing Charge of Discrimination, that the matters stated are true and correct to the best of my knowledge, information, and belief, and that I am authorized to file this Charge.

I understand that this Charge will be filed with the Colorado Civil Rights Division and the U.S. Equal Employment Opportunity Commission and that statements made herein may be disclosed to Respondent during the course of the investigation.

Date: [__/__/____]

[________________________________]

[CHARGING PARTY NAME], Charging Party

STATE OF COLORADO

COUNTY OF [______________________] ss.

Subscribed and sworn to before me this [____] day of [_______________], 20[____], by [CHARGING PARTY NAME].

[________________________________]

Notary Public

My commission expires: [_______________]

10. CERTIFICATE OF MAILING

I hereby certify that on [__/__/____], I submitted the foregoing Charge of Discrimination to:

Colorado Civil Rights Division
1560 Broadway, Suite 825
Denver, CO 80202
Phone: (303) 894-2997
Online intake: https://ccrd.colorado.gov/

U.S. Equal Employment Opportunity Commission — Denver Field Office
950 17th Street, Suite 300
Denver, CO 80202
Phone: (800) 669-4000
Online portal: https://publicportal.eeoc.gov/

Method of submission: ☐ CCRD Online Intake Portal ☐ U.S. Mail (certified, return receipt) ☐ In-person delivery ☐ EEOC Public Portal

[________________________________]

[CHARGING PARTY / COUNSEL NAME]

11. COLORADO PRACTICE NOTES

• Online intake first. CCRD requires an online Intake Inquiry Questionnaire at ccrd.colorado.gov before the formal Charge is docketed. The questionnaire is not the Charge — only a verified, signed Charge tolls the limitations period.

• 300-day employment-charge deadline. C.R.S. § 24-34-403, amended by HB 22-1367 effective August 10, 2022, requires an employment-discrimination charge within 300 days after the alleged practice. File early; other types of charges can have different deadlines.

• Dual filing with EEOC. A charge filed with CCRD is automatically deemed filed with EEOC (and vice versa) under the worksharing agreement. Specify dual-filing on the form and request EEOC investigation under Title VII / ADA / ADEA where applicable.

• Investigation timeline. Commission jurisdiction ceases if written notice of a formal hearing is not served within 450 days after the charge is filed, subject to the other events in C.R.S. § 24-34-306(11)(a). Respondent and charging-party response periods depend on the current agency rules and notices.

• Mediation. CCRD offers voluntary mediation early in the process. Mediation is confidential and frequently produces a faster, more flexible result than litigation.

• Probable-cause vs. no-probable-cause determination. A probable-cause finding triggers conciliation and, if unsuccessful, a public hearing before an Administrative Law Judge. After a no-probable-cause dismissal, the director's notice must advise the charging party of the appeal option and the separate deadline for a state district-court action under C.R.S. § 24-34-306(2)(b)(I).

• Right to sue and civil-action clock. Receipt of a CCRD right-to-sue notice ends commission jurisdiction under C.R.S. § 24-34-306(11)(a)(II); subsection (11)(b) requires a state civil action within 90 days after jurisdiction ceases. A no-probable-cause dismissal uses the separate notice and appeal deadlines in subsection (2)(b)(I)(B). Subsection (15) governs requesting the right-to-sue notice. Federal counts have a separate EEOC notice and filing period under 42 U.S.C. § 2000e-5(f)(1).

• Scope of later civil action. Claims in a later civil suit must be either expressly raised in the Charge or "reasonably related" to the scope of the CCRD/EEOC investigation. Plead broadly in the Charge — but truthfully — to preserve later claims.

• Harassment standard (POWR Act). For acts on or after August 7, 2023, harassment need not be "severe or pervasive." C.R.S. § 24-34-402(1.3)(a) requires conduct or communication directed at actual or perceived protected-class membership that is subjectively offensive to the complainant and objectively offensive to a reasonable person in the same protected class.

• Marital status. Marital status is now a protected class in employment. C.R.S. § 24-34-402(1)(a).

• Disability accommodation defense. The "significant impact on the job" defense to reasonable accommodation has been eliminated. Respondent must rely on the narrower "undue hardship" or "direct threat" defenses.

• Recordkeeping. Employers must retain personnel and employment records for at least 5 years (POWR Act). Charging Party should request these records in any rebuttal.

• Public accommodations and housing. Different sub-parts of CADA govern: employment (Part 4), housing (Part 5), public accommodations (Part 6). Filing windows and procedures vary; verify before submission.

• Damages caps remain in CADA employment cases. The POWR Act did not eliminate the employment damages caps in C.R.S. § 24-34-405(3)(d); former subsection (3)(g) is repealed. HB 25-1239 (effective August 6, 2025) reorganizes public-accommodation/disability remedies but does not uncap CADA employment damages.

• Aiding and abetting. C.R.S. § 24-34-402(1)(e)(I) prohibits any person from aiding or abetting discriminatory employment practices. Identify each respondent and the supporting conduct, but do not infer a personal damages remedy against a supervisor from that prohibition alone.

• Confidentiality. CCRD investigation files are confidential while the matter is open. Both parties may inspect each other's submissions but may not publicly disseminate them.

12. SOURCES AND REFERENCES

• Colorado Civil Rights Division (CCRD) — https://ccrd.colorado.gov/
• CCRD Complaint Process — https://ccrd.colorado.gov/the-complaint-process
• CCRD Common Civil Rights Questions — https://ccrd.colorado.gov/common-civil-rights-questions
• 3 C.C.R. 708-1 (Colorado Civil Rights Commission Rules and Regulations) — https://ccrd.colorado.gov/sites/ccrd/files/documents/3CCR708-1-Colorado-Civil-Rights-Commission-Rules-and-Regulations.pdf
• Colorado Anti-Discrimination Act, C.R.S. § 24-34-301 et seq. — https://leg.colorado.gov/
• C.R.S. § 24-34-306 (Procedure on filing a charge) — https://leg.colorado.gov/
• C.R.S. § 24-34-403 (Limitation period — 300 days) — https://leg.colorado.gov/
• C.R.S. § 24-34-405 (Relief authorized; damages caps) — https://leg.colorado.gov/
• SB 23-172 (POWR Act, eff. Aug. 7, 2023) — https://leg.colorado.gov/bills/sb23-172
• HB 13-1136 (Job Protection and Civil Rights Enforcement Act) — https://leg.colorado.gov/
• HB 25-1239 (CADA Remedies Modification) — https://leg.colorado.gov/bills/hb25-1239
• U.S. Equal Employment Opportunity Commission — https://www.eeoc.gov/
• EEOC Denver Field Office — https://www.eeoc.gov/field-office/denver/location
• EEOC Public Portal — https://publicportal.eeoc.gov/
• National Railroad Passenger Corp. v. Morgan, 536 U.S. 101 (2002) (continuing-violation doctrine)
• Bostock v. Clayton County, 590 U.S. 644 (2020) (sex discrimination includes sexual orientation and gender identity)

Disclaimer: This template is provided for informational purposes only and does not constitute legal advice. An attorney licensed in Colorado must review and customize this Charge before submission. CCRD intake processes, deadlines, and forms change periodically; verify current procedures at ccrd.colorado.gov before filing.