TAMPA – A Florida woman claims her current employer is discriminating against her due to her race and disability, denying her commission opportunities, offering her “materially inferior” compensation terms and constructively demoting her.
Plaintiff Courtney LaCroix, who is Black, filed her lawsuit in U.S. District Court for the Middle District of Florida, Tampa Division.
LaCroix, a longtime employee of defendant The Fountain Group LLC, claims the company has violated the federal Civil Rights Act, the Americans with Disabilities Act, and the Florida Civil Rights Act.
The Fountain Group is a professional staffing firm headquartered in Tampa. LaCroix has worked for the company as a recruiter, senior recruiter, recruiting team lead, and delivery manager.
LaCroix, 38, claims she has been diagnosed with anxiety and depression, for which she has been prescribed medication and been under the care of multiple mental health providers.
“Plaintiff’s anxiety and depression substantially limit one or more major life activities, including but not limited to concentrating, sleeping, interacting with others, and regulating her emotions,” her 34-page complaint states.
She alleges her “demanding” work hours – often 12-hour shifts – “significantly contributed” to the development and worsening of her depression and anxiety. She contends she has been open with her supervisors about her condition and treatment.
After an Aug. 1, 2024 meeting that LaCroix describes in her filing as “highly emotional” and “distressing,” she experienced a panic attack. Afterwards, she emailed her supervisor and informed him that she would be taking off the remainder of that Thursday and the day after.
She notes in her complaint that she had a pre-approved half-day PTO already scheduled for Aug. 2, 2024 prior to the meeting and a pre-approved PTO day scheduled for Monday, Aug. 5, 2024.
On Aug. 6, 2024, LaCroix claims she emailed her supervisor explaining her need to step down from her position due to her mental health struggles.
However, she ultimately decided to remain in her position after finding out she would not retain her commission eligibility if she transitioned out of her management role.
Similarly-situated white employees, she argues, had been allowed to retain commission eligibility or commission-bearing compensation structures.
“At no time during the August 6, 2024 meeting, or at any other time, did Defendant engage in the interactive process required under the ADA, explore potential reasonable accommodations for Plaintiff’s disability, or inform Plaintiff that an ADA accommodation process through ADP was available to employees seeking mental health accommodations,” the complaint states.
Soon after, LaCroix alleges her supervisor issued a disciplinary write-up against her, citing her alleged failure to properly communicate before leaving work Aug. 1, 2024, and asserting her team had been left unattended.
“Plaintiff alleges that the disciplinary write-up was retaliatory and was issued shortly after she complained to Human Resources about discriminatory treatment and disclosed her disability-related need for relief from the Delivery Manager role,” the filing states.
In February 2025, LaCroix claims she again emailed her supervisor and Hunter Cone, the defendant’s owner, to formally communicate her intention to step down from her delivery manager position due to her ongoing mental health struggles.
A meeting was held, in which LaCroix was offered a senior recruiter position at a base salary of $85,000 per year with no commission structure.
“Defendant’s offer represented an estimated annual financial loss of approximately $45,000 based on Plaintiff’s prior total annual compensation of between approximately $130,000 and $155,000,” the lawsuit states. “The standard compensation model for a Senior Recruiter at Defendant is a base salary of approximately $51,000 plus commission eligibility.
“Plaintiff was not given the option to select the standard Senior Recruiter compensation plan.”
LaCroix claims she was the only former delivery manager offered a senior recruiter role with no commission eligibility at all.
“Plaintiff was constructively demoted because Defendant presented her with no viable options: remain in a leadership role with ongoing and unaddressed disability-related conflict; accept a lower-ranking Senior Recruiter position stripped of the commission structure she had earned for years; or resign entirely,” the complaint states.
She seeks back pay, front pay, lost commission income, lost benefits, and other economic damages, in addition to compensatory damages for emotional distress, humiliation, and mental anguish. She also seeks pre- and post-judgment interest and attorney fees.
Imler Law in Lutz, Florida, is representing LaCroix in the action.
