Dominguez-Curry

Background

Since 1994, Dominguez has worked under the supervision of Roc Stacey in the Nevada Department of Transportation’s contract compliance division. Stacey routinely made demean- ing comments to women in the division. For example, Stacey told Dominguez and two other women in the division that “he wished he could get men to do [their] jobs,” that “women have no business in construction,” and that “women should only be in subservient positions.” In response to a work- related question from Dominguez, Stacey replied, “if you girls were men, you would know that.” Referring to Dominguez and other women in the division, Stacey said, “You guys are being paid more than you even should be getting paid.” Fur- ther, Stacey called the division’s female assistant “stupid,” and on one occasion, he kicked another female employee’s chair while she was sitting in it because he was upset with her.

Stacey also told sexually explicit jokes in the workplace. Dominguez described the jokes as “the blond with the big tits type jokes and what she did with whom and those types of jokes.” Dominguez said “those were like everyday jokes.”

Shortly after Dominguez began working for Stacey, Stacey…