top of page


Friday, November 25, 2022

JD Howlette Law Files Unlawful Sex-Based Discrimination Lawsuit Against U.S. Citizenship and Immigration Services

November 25, 2022 - JD Howlette Law announced today that it filed a federal civil rights lawsuit against the United States Citizenship and Immigration Services (USCIS) in the Southern District of Florida on behalf of Immigration Officer Yadira Dominguez. According to the amended complaint, the management team at the Fraud Detection and National Security Directorate (FDNS) office in Miami, Florida engaged in persistent acts of unlawful sex-based discrimination and retaliation against Ms. Dominguez for several years. Ms. Dominguez claims that, despite her years of stellar work performance and professional accolades, Defendants began targeting her following a complaint she made reporting inappropriate conduct on the part of her male supervisor.  

The amended complaint alleges that Defendants forced Ms. Dominguez—a Hispanic female and mother to two minor children—to endure a nearly 4-year long hostile and toxic work environment replete with acts of racism, sexism, misogyny, intimidation, humiliation, discrimination, and retaliation. Ms. Dominguez alleges that Defendants’ unlawful conduct consisted of, among other things:

  1. Showing up unannounced to her personal residence during the workday to “check” on her;

  2. Manipulating her time and attendance records;

  3. Treating her less favorably than other similarly-situated employees when it comes to employee benefits and flexible workplace policies;

  4. Repeatedly charging her with absence without leave (“AWOL”) instead of allowing her to use accrued sick leave or annual leave;

  5. Repeatedly denying her requests to use accrued sick leave while allowing other employees to use the same;

  6. Scrutinizing her work product in an excessive and unjustified manner relative to the same work product submitted by other similarly situated employees; and

  7. Revoking her telework privileges in the middle of the COVID-19 pandemic without any legitimate reason for doing so.


According to Ms. Dominguez, her first-line supervisor is well-known for making disparaging and offensive remarks about females working in upper management at the office, all of whom are minorities. For instance, the supervisor has repeatedly referred to female managers as “the b-word,” negatively referred to the female Field Office Director as “Big Mama,” and has made offensive statements regarding Hispanic and/or Latino cultures. Ms. Dominguez alleges that despite her persistent and passionate pleas for help, Defendants failed to take adequate remedial measures to protect her right to work in an environment free from unlawful discrimination, retaliation, or other inappropriate workplace misconduct.

As far as harm, the amended complaint alleges that Ms. Dominguez has been forced to seek professional therapy services, consume prescription medications, and undergo emergency medical treatment as a means of coping with the high levels of anxiety, depression, and trauma inflicted upon her by Defendants’ unlawful conduct. Ms. Dominguez also claims to have expended nearly $90,000 on legal fees in her efforts to vindicate her civil rights before the Equal Employment Opportunity Commission.

"As a former trial attorney with the U.S. Department of Justice, I am deeply saddened and disturbed by the Department of Homeland Security's failure to swiftly quash the hostile and toxic work environment festering within the FDNS at its Kendall Field Office. Neither Ms. Dominguez nor any other female employee should ever feel compelled to work in an environment where women are treated inferior to men—those days need only find solace in the history books. Now that we're in federal court, I look forward to vigorously fighting to protect Ms. Dominguez’s right to work in an environment free of discrimination while simultaneously holding the FDNS management team accountable for their deplorable actions." - Jordan D. Howlette, Managing Attorney of JD Howlette Law.

The amended complaint alleges that Defendants’ actions violated Title VII of the Civil Rights Act of 1964, as amended, which prohibits federal agencies like USCIS from engaging in discriminatory personnel actions based on race, color, religion, sex, or national origin, and from retaliating against an employee for participating in the Equal Employment Opportunity (EEO) process. In addition to compensatory damages, Ms. Dominguez seeks an injunction requiring managers and supervisors in the FDNS at the Kendall Field Office to complete annual employment discrimination training, in a manner and format approved by the U.S. Equal Employment Opportunity Commission.

JD Howlette Law provides high-quality civil litigation services to clients throughout the District of Columbia, Maryland, Virginia, and Florida. The firm dedicates a significant portion of its practice to representing clients in disputes involving violations of civil rights and individual liberties. For more information, visit or call (202) 921-6080.

bottom of page