Raymond Laborde Correctional Center in Cottonport
ALEXANDRIA, La. – A female master sergeant at a Louisiana correctional facility last month sued the state Department of Public Safety and Corrections for claims of sexual harassment and discrimination.
Plaintiff Danielle Nicholson filed her complaint February 27 in U.S. District Court for the Western District of Louisiana.
Nicholson worked for the defendant at the Raymond Laborde Correctional Center facility in Cottonport, Avoyelles Parish, as a master sergeant in support services and maintenance from October 2019 to March 2024.
In her seven-page complaint, she alleges the corrections department illegally discriminated against her based on her sex in violation of the Civil Rights Act and the Louisiana Employment Discrimination Law.
“Though Plaintiff attempted to remain in her position at Defendant’s Raymond Laborde Correctional Center, it was made very clear to her that, despite her complaints, no action would be taken, at any level of management, to address her complaint or protect her from Mr. Lacombe’s unlawful behavior towards her,” the complaint states.
She alleges in her filing that she was subjected to sexual harassment by Lieutenant Jody Lacombe. Lacombe worked in the gymnasium at the correctional center and would often pick up equipment from the supply room within the maintenance shop, she claims.
Lacombe “frequently” would ask Nicholson, while also in the supply room, about her personal life, including romantic relationships, she claims.
However, things escalated on Feb. 24, 2023 when Lacombe messaged Nicholson, telling her, “I just [took] 3 Viagra’s and now wifey [is] passed out!! Can u help??????”
“Mr. Lacombe asked Plaintiff to go camping with him saying they could ‘fish, fight or f**k if [she] wanted to,’” the complaint states.
Nicholson claims he also messaged her asking if she would perform oral sex on him at work.
After suffering a miscarriage in May 2023 and taking leave until June 31, 2023, Nicholson returned and reported Lacombe’s “harassing behavior” to her immediate supervisor and provided screenshots of the messages Lacombe had sent her.
That supervisor contacted her supervisor, who then met with Nicholson and read the messages. He assured Nicholson that he would “take care of it” and promised to keep Lacombe away from Nicholson.
“Despite these assurances from Plaintiff’s supervisors, Mr. Lacombe remained in his position and continued to harass Plaintiff,” the complaint states.
Nicholson alleges that after finding out she had reported his behavior, Lacombe “resorted to verbal abuse.” He also increased the frequency in which he would come to the maintenance shop, and asked “persistent” questions about her daughter, whom she had miscarried.
“Mr. Lacombe even told Plaintiff that her miscarriage and loss of her daughter was a positive event, because ‘the world didn’t need two of [Plaintiff] in it.’ And ‘no one would want to date [Plaintiff] if she had two children,’” the filing states.
Nicholson elevated her sexual harassment complaint to the Unit 2 Warden, whom set up a meeting with Nicholson and the chief of security, Joseph Hext.
“Warden Hext responded to Plaintiff’s complaint of sexual harassment by telling her, ‘this happened months ago, you should be over this by now.’ He also told Plaintiff that Defendant was not going to make an effort to keep Mr. Lacombe away from her,” she claims in her complaint.
In January 2024, Nicholson went on to report Lacombe’s harassment to Head Warden Marcus Myers. Myers allegedly told Nicholson he wasn’t going to fire Lacombe or make an effort to keep him away from her.
Nicholson claims Myers even suggested that she should move her schedule to work night shifts to avoid Lacombe, who worked day shifts.
After the meeting, Nicholson claims she filed a verbal report with an intake specialist at the corrections department’s main office. She was “assured” that an investigator would be assigned to the complaint and would reach out in one to two days. But Nicholson claims she never heard from anyone.
Meanwhile, Lacombe continued to harass Nicholson, she alleges.
Nicholson was constructively discharged March 25, 2024 due to the corrections department’s “complete failure to take prompt remedial action for the sexually hostile work environment in which she was forced to work,” her filing states.
Constructive discharge, in legal terms, refers to an employee's resignation being treated as if they were fired, even though they technically quit. This happens when an employer creates working conditions so intolerable that a reasonable person would feel compelled to resign.
Nicholson seeks back pay plus interest, front pay, benefits, compensatory damages, punitive damages, pre- and post-judgment interest, and attorneys’ fees. She also wants the defendant to be ordered to require sexual harassment training.
Bohrer Brady LLC in Baton Rouge and Ellwanger Henderson LLLP in Austin are representing her in the lawsuit.
