Tracie Dahl says she was working for U.S. Customs and Border Protection in Havre, Mont., when Christopher Clark, then deputy chief of staff to the commissioner in the Homeland Security’s District of Columbia office, interviewed her and hired her for a job in Washington, D.C.
She claims Clark began his long campaign of sexual harassment with “unsolicited and unwelcomed” personal emails before she even moved to Washington. She claims his unwelcome attentions progressed to invitations to “enjoy his beach house,” and that he insisted on joining her on her drive from Montana to her new job.
From late July to August 2007, Dahl says, Clark wrote to her about “taking her to wine tastings,” and that he “would like to see the plaintiff’s tattoo and also see her in a sundress.”
“Clark also wanted to see how good plaintiff’s tongue was and that he was attracted to the plaintiff,” according to the complaint.
Dahl claims Clark traveled to Montana on Aug. 8 “under the guise of an official business trip” and asked her to meet him. She says he made her feel “that she did not have a choice but to do whatever he suggested or he would fire her.”
That night Clark took her back to his hotel room “where he demanded to have sex and forced himself on her and, after initially attempting to fight him off, she gave up and he had his way,” the complaint states. It adds: “The sex was not of her free will and was unwelcomed.”
A week later, she says, Clark e-mailed her the lyrics to Jimmy Buffett’s song “Come Monday” and wrote about “loving” her.
Dahl claims Clark met her in Minneapolis to join her for her move to Washington and “demanded sex” on each of the four nights they spent on the road.
Once in Washington in her new job, she says she tried to refuse to have sex with him, but “Clark exhibited an attitude including body language which conveyed that he was entitled to have sex with the plaintiff if she wanted to maintain her job and it so scared the plaintiff that she backed off her stance and even suggested make-up sex.”
Clark also monitored her in Washington, “particularly her movements and communications with other people and he sought to restrict, insulate and isolate the plaintiff so as to maintain and continue his control and dominion over her,” she claims.
“There was an expectation that the plaintiff would be providing Clark sex and he treated the plaintiff as if she was his sex slave,” the complaint states.
Dahl says she filed an EEO complaint alleging sexual harassment after two Internal Affair agents questioned her about the relationship.
She says the agents and her other supervisors determined that the relationship was consensual, and the agency denied her transfer request and “reduced and denied the plaintiff any work assignments over several weeks and months.”
Dahl says she suffered anxiety and panic attacks and “had no other option but to submit her resignation.”
She sued DHS Secretary Janet Napolitano, seeking reinstatement, lost wages and $500,000 for sexual harassment and retaliation. She is represented by Boniface Cobbina.
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