Complaint Against JAY DEV, LLC , Filed by Lorraine Sanchez.(karpf, ARI)
INTRODUCTION
1This action has been initiated by Plaintiff against Defendant Jay Dev LLC d/b/a Dunkin Donuts (hereinafter referred to as “Defendant” unless indicated otherwise) for violations of Title VII of the of the Civil Rights Act of 1964, the Pennsylvania Human Relations Act (“PHRA”)1 and the Pennsylvania Wage and Collection Law (“WPCL” - 43 P.S. §§ 260.1 et. seq.). Plaintiff asserts, inter alia, that she experienced unlawful workplace discrimination and retaliation, culminating in her termination from Defendant. As a direct consequence of Defendant’s unlawful actions, Plaintiff seeks damages as set forth herein. 1 Plaintiff’s claims under the PHRA are referenced herein for notice purposes. She is required to wait 1 full year before initiating a lawsuit from date of dual-filing with the EEOC. Plaintiff must however file her lawsuit in advance of same because of the date of issuance of her federal right-to-sue letter under Title VII. Plaintiff’s PHRA claims however will mirror identically her federal claims under Title VII.
JURISDICTION AND VENUE
2This Court has original subject matter jurisdiction over the instant action pursuant to 28 U.S.C. §§1331 and 1343(a)(4) because it arises under laws of the United States and seeks redress for civil rights violations under Title VII.
3This Court may properly maintain personal jurisdiction over Defendant because Defendant’s contacts with this state and this judicial district are sufficient for the exercise of jurisdiction in order to comply with traditional notions of fair play and substantial justice, satisfying the standard set forth by the United States Supreme Court in International Shoe Co. v. Washington, 326 U.S. 310 (1945) and its progeny.
4Pursuant to 28 U.S.C. §1391(b)(1) and (b)(2), venue is properly laid in this district because all of the acts and/or omissions giving rise to the claims set forth herein occurred in this judicial district.
5Plaintiff filed a Charge of discrimination and retaliation with the Equal Employment Opportunity Commission ("EEOC"). Plaintiff has properly exhausted her administrative proceedings before initiating this action by timely filing her Charge with the EEOC, and by filing the instant lawsuit under Title VII within 90 days of receiving a right-to-sue letter from the EEOC.
PARTIES
6The foregoing paragraphs are incorporated herein in their entirety as if set forth in full.
7Plaintiff is an adult individual, with an address as set forth in the caption
8Defendant Jay Dev, LLC is a Pennsylvania corporation that owns and operates restaurants, under the name Dunkin Donuts, with a location at the above-captioned address.
9At all times relevant herein, Defendant acted by and through its agents, servants and/or employees, each of whom acted at all times relevant herein in the course and scope of their employment with and for Defendant.
FACTUAL BACKGROUND
10The foregoing paragraphs are incorporated herein in their entirety as if set forth in full.
11Plaintiff is a member of the Pentecostal Church.
12As a member of the aforementioned Church, Plaintiff’s closely held religious beliefs include different practices, such as women traditionally wearing skirts or dresses, as pants are not typically permitted.
13Plaintiff was hired by Defendant on or about April 1, 2025, as a Crew Member.
14At all times relevant herein, Plaintiff was supervised by manager – Alyson Wentz (hereinafter “Wentz”).
15On or about April 14, 2025, Plaintiff reported to her first regularly scheduled day of work for Defendant.
16On the same day, Wentz sent Plaintiff home for wearing a long denim skirt and not jeans.
17Plaintiff expressed to Wentz that she could not wear jeans due to her strongly held religious beliefs (which precluded her from wearing pants).
18Plaintiff further provided alternative accommodations to Wentz, including wearing long khaki or denim skirts instead, which were permitted by her aforementioned religion.
19In response, Wentz told Plaintiff that she would “speak to management” but was sending her home due to alleged safety concerns.
20Thereafter, Wentz texted Plaintiff an ultimatum of either giving up her closely held religious beliefs by wearing pants to work or losing her job.
21Specifically, Wentz stated “So I was told that it is Dunkin policy to wear pants and if you cannot do that I completely understand, no hard feelings.”
22In response to the aforementioned, Plaintiff responded “I know this wasn’t your call but I do [want] to ask who made the final decision and do you think if I would speak for myself and explain my religion which also requires me to not wear makeup, earrings, etc., And possibly change the outcome rather than fire me.”
23In response to Plaintiff’s question, Wentz sent a text to Plaintiff with a screenshot of Google AI search (purportedly received from Defendant’s owner) which outlines why skirts may allegedly not be safe in the work place and stated “It’s just not safe” and “It’s also not going to change the outcome,” referring to Plaintiff’s religious beliefs and need for a religious accommodation (of wearing a long skirt instead of pants).
24Upon information and belief, Dunkin franchises (including Defendant) allow employees to wear garments other than pants which would pose more of a safety hazard than that of a long skirt, even allowing employees to wear shorts if they choose.
25Plaintiff’s requested accommodation caused no undue hardship and was easy to grant.
26Plaintiff believes and therefore avers that her religion was a motivating or determinative factor in Defendant’s decision to terminate her employment.
27Plaintiff also believes and therefore avers that she was terminated in retaliation for engaging in protected activity under Title VII, including for requesting an accommodation.
28Plaintiff further avers that Defendant’s refused to engage in the interactive process and accommodate her requests for a religious accommodation.
COUNT I
Violations of Title VII of the Civil Rights Act of 1964 (“Title VII”)
([1] Religious Discrimination & [2] Retaliation)
29The foregoing paragraphs are incorporated herein in their entirety as if set forth in full.
30Plaintiff believes and therefore avers that her religion was a motivating or determinative factor in Defendant’s decision to terminate her employment.
31Plaintiff also believes that Defendant terminated her in retaliation for requesting a religious accommodation.
32Lastly, Plaintiff avers that she was terminated as a direct result of Defendant’s failure to engage in the interactive process and/or accommodate her religious beliefs.
33The actions of Defendant, through its agents, servants, and employees, in terminating her employment for discriminatory/retaliatory reasons and/or failing to accommodate her religious beliefs constitute violations of Title VII.
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Public U.S. federal court record (district court docket 73112514, document 1). Source via the RECAP Archive (Free Law Project). The same record is available from PACER. Informational only — not legal advice.