USC and a senior manager of the USC Bookstore, Butch Paredes, are facing a lawsuit alleging race discrimination and harassment of USC graduate and former bookstore student worker.

Cymia Alexander, who previously worked as a cashier for USC Bookstores as part of a work study program, claimed she experienced a hostile work environment because she is a Black woman. The official civil complaint against USC and Paredes was filed on Jan. 20 in the federal court for the Central District of California.

“This is not just a case about one incident of harassment. It’s over a course of my client’s tenure as a student at USC,” Scott Nakama, one of Alexander’s attorneys, told Annenberg Media. “What we’re trying to figure out in this lawsuit is how to prevent this from happening in the future to someone else.”

According to the official complaint, Alexander had her first conversation with Paredes in July 2018, a few months after Paredes was initially hired. During that conversation, Alexander said she informed Paredes that she was told some of her coworkers refused to listen to her because of her skin color. Paredes allegedly responded, “Well, maybe you should just lighten your skin.”

Over the following months, Alexander claims Paredes repeatedly “criticized her, screamed at her, insulted her” and called her a negative person, on one occasion allegedly referring to her as a “bouncer” because he claimed she was loud. Alexander’s lawyers argue in the complaint that Paredes’ use of these terms perpetuated racial stereotypes of the “angry Black woman.” The complaint further alleges that on multiple occasions Paredes dismissed Alexander’s suggestions as “dumb” and later took credit for them, but never did the same with the ideas of non-Black employees.

On another occasion, Alexander said she complained to Paredes that other employees were being rude. Paredes allegedly discouraged Alexander from complaining to the department, saying, “You need to learn how to build relationships… [and] how to talk to people.” According to the lawsuit, when Gabriella Valdez (the assistant manager and a coworker from Paredes’ previous job) made a similar complaint, Paredes did not discourage her from complaining.

On Oct. 25, 2018, Paredes allegedly informed Alexander that he had missing stuff from his desk, which was located in the breakroom. Alexander suggested he move his desk to a different area, at which point Paredes “got angry and started berating” Alexander, according to the complaint.

After that, Paredes had a meeting with Alexander and Valdez. Paredes then asked Alexander if she wanted to leave, to which she responded she would leave after her shift ended. The supervisor started screaming at her, saying that she was “insubordinate” and needed to leave. He called security and requested they escorted her out, but security refused. Paredes then talked to Bookstore Director Darren James and Senior Associate Director Rehab Favia so they could escort Alexander out. Per James’ instructions, Favia asked Alexander to leave early and to not come the next day, the complaint states.

On Oct. 30, 2018, after meeting with a human resources manager, Alexander was transferred to another department in the same building as the bookstore. But this transfer did not stop Paredes’ harassment of Alexander, according to the complaint.

Paredes allegedly complained to Alexander’s new supervisor about her presence in the bookstore, despite this being necessary for Alexander’s new position. According to her lawyers in the lawsuit, Alexander contacted the USC Office of Equity and Diversity in February 2019 and received a response claiming the office would talk to human resources.

The complaint also mentioned that Alexander scheduled an appointment with USC Student Health due to the continued racial harassment and later saw a counselor due to depression, headaches and difficulty focusing.

Alexander graduated in spring of 2019. In June of that year, Alexander visited the bookstore to buy USC apparel but she was informed by a former coworker that she could not enter the bookstore unless she bought something. According to the complaint, Alexander believes the employee was acting under the instructions of Paredes.

In July of 2020, Alexander shared her experience on @black_at_usc, an Instagram account that posts about the experiences of Black USC students.

According to the complaint, Valdez commented on the post claiming it was a lie, that Alexander should have been fired but that Paredes saved her position. The comments have since been deleted.

The complaint states USC concluded an investigation of the allegations in Sept. 2020 and determined the university did not discriminate or retaliate against Alexander.

According to the complaint, Alexander endured harassment not only from her supervisor, but also from other bookstore employees, alleging she received multiple “dirty looks” over the years. Alexander believes that this was due to her race because the employees did not look at other, non-Black co-workers like that.

In one instance, the complaint says Alexander (who was promoted to supervisor by this point) instructed another employee to do some tasks. That employee allegedly later told another employee that she would not listen to Alexander because “Alexander’s skin was too dark.”

In fall 2017, Alexander claimed a group of coworkers pretended to not hear her instructions on their work radios when other employees could hear her fine.

In response to a request for comment, USC offered this official statement: “The University does not tolerate any form of discrimination, harassment or retaliation and we have created the Office for Equity, Equal Opportunity and Title IX to respond in a timely manner to all such reports and offer support and resolution. Personnel matters are confidential, so we are not able to provide further comment at this time.”

Annenberg Media reached out to Alexander, Paredes and Valdez. None of them responded before publication.

Nakama said he has not spoken directly with other student workers making similar allegations to Alexander’s, but has “seen other lawsuits against USC about inadequate investigations.” USC has faced allegations of inadequate investigations and recently settled lawsuits in excess of $1.1 billion for cases related to campus gynecologist George Tyndall.

One current USC student who worked at the USC Bookstore from fall 2018 until fall 2019 said they were not surprised by the allegations. The student requested to remain anonymous out of fear of retribution for speaking out.

“There was a disconnect between the managers and the workers,” the student said. They said there was hostility between the managers and the workers, pointing to a time when two managers made negative comments about another worker behind that employee’s back. The student said they worried the same might happen to them.

“You could tell who the managers favored... because they received a different type of treatment,” said the student.

Though the case is in its “relatively early stages,” according to Nakama, Alexander and her team are hopeful about the outcome.

“We just want some change and some accountability,” said Nakama.