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Attorney General Matthew J. Platkin and the Division on Civil Rights (DCR) announced today that DCR has filed a complaint in Superior Court against Ironworkers Local 11, a New Jersey labor union that operates a hiring hall, for allegedly violating the New Jersey Law Against Discrimination (LAD) by creating and maintaining a hostile work environment and by systematically bypassing Black union members for jobs and giving such workers less desirable assignments.

The complaint filed today alleges that Local 11 – a New Jersey chapter of the International Association of Bridge, Structural, Ornamental and Reinforcing Ironworkers Union, AFL-CIO – created a hostile work environment that resulted in discrimination against union members based on race, sexual orientation, and sex. According to the complaint, Local 11’s leadership and members – including Raymond Woodall, who served as Local 11’s business manager from 2008 to 2022 – repeatedly used racist slurs, including the “n” word and the word “shine.” They also used homophobic and sexist language and distributed homophobic materials in the workplace. Yet Local 11’s leadership took no effective action to stop, prevent, or remedy racist, homophobic, and sexist language or conduct in the workplace.

The complaint also alleges that Local 11 discriminated against Black members seeking ironwork assignments through the union hiring hall. According to the complaint, Local 11 repeatedly bypassed qualified Black union members for jobs in favor of similarly situated non-Black members.

“No one should be subjected to racism, discrimination, or harassment in the workplace, and we are committed to rooting out such despicable conduct,” said Attorney General Platkin. “If you violate our laws, we will hold you accountable. We do not tolerate discrimination in New Jersey.”

“Under our civil rights laws, union members in New Jersey have a right to work in an environment free from discrimination and harassment. Local 11’s reprehensible actions in this case strike at the very heart of that right,” said Sundeep Iyer, Director of the Division on Civil Rights. “The complaint filed today underscores our commitment to combating race discrimination and race-, sexual orientation-, or sex-based harassment wherever it rears its ugly head.”

The case arose after Kesha Green, a Black woman who is a former ironworker and member of Local 11, filed a verified complaint with DCR alleging violations of the LAD. Following an investigation, DCR issued a Finding of Probable Cause, concluding that the evidence was sufficient to support a reasonable suspicion that Green was subjected to differential treatment based on race, that Local 11 maintained a hostile work environment, and that Local 11 retaliated against Green for raising complaints.

The complaint filed today alleges that Local 11 engaged in a broad pattern or practice of discrimination in violation of the LAD. It alleges that Local 11 discriminated not only against Green, but also against many of its other members.

As the complaint alleges, Local 11 maintained a hostile work environment where, among other things, one Black female former union member was called the “n” word, locked in a bathroom for hours at a time, and repeatedly smacked on the buttocks; where employees received pornographic images with homophobic messages; and where Woodall, the business manager, used the “n” word in the presence of other union members, and used the derogatory term “split tails” to refer to women.

Despite being aware of discriminatory conduct and comments in the workplace, Local 11 made no meaningful effort to discipline those engaged in discriminatory conduct, engage in further investigation, or otherwise prevent such conduct from occurring.

The complaint filed today also alleges that Local 11 discriminated against Black union members by systematically bypassing them for jobs. According to the complaint, Local 11 maintained a job referral book in its union hall. Local 11’s stated policy was that it would distribute job assignments to members in the order in which members signed the physical referral book. DCR’s investigation found that Local 11 regularly skipped over Black union members in favor of non-Black union members who signed the referral book after a Black union member. The complaint also alleges that, even when they did eventually receive job assignments, Black union members received inferior assignments that were shorter in duration.

In the complaint, DCR has requested that the Superior Court issue an injunction to bar Local 11 from engaging in conduct or other employment practices that create a hostile environment resulting in discrimination based on race, sexual orientation, and sex, and from maintaining policies and practices that result in Black union members being denied job assignments or receiving inferior job assignments based on race. DCR has also requested that Local 11 pay damages for economic loss and other harms suffered by victims of Defendants’ discriminatory practices, as well as civil penalties for Defendants’ violations of the LAD.

The DCR investigation was led by Justin Hoffer and Legal Specialist Carlos Bellido, under the supervision of Deputy Director Rosemary DiSavino. The complaint is being handled by Division of Law Civil Rights Assistant Section Chief Farng-Yi D. Foo and Deputy Attorneys General Douglas Praschak, Mia Dohrmann, and Jillian Ollwerther under the supervision of Civil Rights Section Chief Nancy Trasande, Assistant Attorney General Mayur Saxena and Deputy Director Sara Gregory of the Division of Law’s Affirmative Civil Enforcement Practice Group.

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DCR is the state agency responsible for preventing and eliminating discrimination and bias-based harassment in employment, housing, and places of public accommodation (e.g., places open to the public like schools, businesses, hospitals, etc.) by enforcing the New Jersey Law Against Discrimination (LAD), the Fair Chance in Housing Act (FCHA), and the New Jersey Family Leave Act.

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