Georgia ADA Retaliation/Wrongful Termination – Goodwill of North Georgia (Smyrna/Marietta) – Seeking Contingency Counsel
CONTACT:
Tyrell Dunn (on behalf of employee Curtis Primes)
EMPLOYER: Goodwill of North Georgia – Retail location: 3205 South Cobb Dr SE, Smyrna, GA 30080 (Smyrna/Marietta). Large employer (500+), so federal damage caps likely at the highest tier.
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TL;DR (for attorneys)
Documented seizure disorder (medical ID). Two earlier ADA incidents (denied accommodation during seizure episode; demotion after hospitalization) + evidence suppression by a manager. Most recent: 9/21/2025, equipment failure injury → hours later a coerced, hearsay-based drug test demand (with District Manager on phone, Store Manager driving, threats about transportation home and termination), employee takes seizure meds that can cause positives → employee declines under coercive conditions → placed on leave → now terminated on “job abandonment” + “failure to test.” Video corroboration exists for prior vomiting/slumping episode; HR previously acknowledged manager withheld the employee’s signed statement. We want reinstatement and to stop the retaliation; otherwise ready to file EEOC and pursue damages. We prefer contingency (paid at recovery).
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## Parties / Roles
Employee: Curtis Primes (retail associate; formerly in management). Documented seizure disorder; wears medical ID necklace/dog tag.
Complainant/Advocate: Tyrell Dunn (brother), corresponding with HR on Curtis’s behalf.
Managers Involved:
Keosha – Assistant General Manager (AGM) involved in earlier ADA incident and evidence withholding.
Jennifer – Store Manager (initiated 9/21 office meeting; attempted to drive employee to drug test).
DeMarcus – District Manager (on phone during 9/21 meeting; raised termination threat).
HR Contacts (email chain): Mr. Ivanov, Mr. Bowers, Mr. Saunders (HR leadership group handling the matter).
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## Chronology (Condensed)
(A) Prior medical history known to employer
Curtis has a seizure disorder, wears a visible medical ID with his name/condition. Employer aware.
(B) Earlier incident – hospitalization & demotion
Curtis suffered a serious seizure outside work, blacked out, woke in an ambulance; was hospitalized.
On return, instead of support/accommodation, he was demoted from management to associate, was unable to clock in for several days, and his management role was quickly filled. We view this as retaliation tied to his medical condition.
(C) Second incident – seizure crisis at work; accommodation denied
While on shift, Curtis experienced classic aura (headache/dizziness) and asked to sit.
AGM Keosha told him essentially to keep the line moving and denied the request.
Curtis, disoriented, slumped at the register and vomited while serving customers.
He was then taken to the office (no cameras) instead of being allowed to leave; on exit, in a disoriented state, he accidentally damaged a door; later collapsed at a bus stop for over 2 hours.
He was placed on “administrative leave.”
HR review later confirmed the video shows him slumped/vomiting at register and reinstated him.
HR also discovered that Keosha had withheld his handwritten, signed statement, locking it in a safe, only producing it when HR specifically requested it.
Note: “Administrative leave” was applied to him as an associate, which we contend was an inconsistent elevation of discipline.
(D) Third incident – 9/21/2025 (Keosha’s first day back from leave)
Curtis flagged a damaged dresser with a loose leg; asked Store Manager Jennifer if he should repair (e.g., screw it). She said to "Grade A it" (top price).
While lifting the dresser alone onto his flatbed, the leg failed, the piece shifted, and he chipped a fingernail; he taped it for comfort. Jennifer saw the result, asked if he was okay; he said yes and returned to work.
Hours later, after lunch, Jennifer called him into the office; District Manager DeMarcus was already on the phone.
Jennifer alleged "four people said you smell like marijuana" and directed an immediate drug test.
Jennifer said she would personally drive him (with a training manager). During the drive-out prep, with DeMarcus on the phone, she asked how he would get home if he didn’t pass. DeMarcus warned that refusal would be termination.
Curtis takes prescribed seizure medication that can cause positives on some panels. The combo of transportation threat, termination threat, and medication risk made this a coercive, discriminatory demand. Curtis said he was not refusing but declined under those coercive conditions (he walks to work on weekends and reasonably feared being stranded).
He was then placed on leave again.
Shortly after we issued a written 4-day resolution notice (9/22 → 9/26), HR terminated him on “job abandonment” and “failure to take drug test.”
(E) HR handling
The supportive HR rep who previously verified the video and reinstated Curtis was out on vacation; upon return, we’re told the case was taken off his desk.
We contacted him; he informally indicated he would try to reach higher management, but official action came from others: termination for “abandonment/failure to test.”
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## Evidence on Hand / To Preserve
CCTV footage of vomiting/slumping at register (prior incident) – HR already confirmed it exists and supports Curtis.
CCTV 9/21/2025: sales floor area where the dresser leg failed, register, office, entrance/exit, and any areas showing the escort/drive preparation.
Handwritten signed statement (the one Keosha withheld); HR confirmed it was locked in a safe.
Email chain with HR (demands, timelines, 4-day notice, follow-up).
Witnesses (coworkers) who can confirm the damaged furniture warnings, the chipped fingernail, and the timing of the drug allegation.
Medical records & prescription confirming seizure disorder and medication that may trigger a false positive.
Texts and notes of prior demotion after hospitalization; scheduling/clock-in issues; leave notices; and termination communications.
Names/titles of decisionmakers: Keosha (AGM), Jennifer (Store Manager), DeMarcus (District Manager); HR leadership (Mr. Ivanov, Mr. Bowers, Mr. Saunders) on the email threads.
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## Legal Issues (as we see them)
1. ADA – Failure to accommodate (denial of brief, reasonable request to sit during seizure onset → vomiting, collapse).
2. ADA – Retaliation (demotion after hospitalization; administrative leave; coerced drug-test demand; suspension/leave; termination after asserting ADA rights).
3. Evidence suppression / spoliation risk (manager withheld the signed statement; need preservation letter for CCTV, witness notes, call logs).
4. Unsafe workplace practices (known damaged dresser left on floor; injury when leg failed; pivot to drug allegation instead of incident reporting/comp filing).
5. Coercive/biased testing demand (threats about transportation and termination, no accommodation for seizure medication that may false-positive).
6. Wrongful termination / defamation (false “job abandonment” and “refusal” pretexts following protected activity).
Venue: Georgia (Cobb County worksite). Large employer (500+ employees) → damages cap tier at the highest level for compensatory/punitive under federal statutes.
Deadlines: EEOC charge window applies (time-sensitive); we understand Georgia’s private-sector cases have a short federal deadline (commonly 180 days) to file an EEOC charge—we are within it and ready to proceed.
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## What We Want
Primary: Immediate reinstatement and written assurances of non-retaliation and proper ADA accommodations going forward.
If not resolved promptly: File EEOC and pursue back pay, front pay, compensatory/punitive damages, attorneys’ fees, and corrective injunctive relief.
We are willing to consider a pre-suit resolution if it restores employment and safety and clears Curtis’s record.
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## Representation Requested (Contingency)
We’re seeking Georgia employment counsel to take this on a contingency basis (paid from recovery/settlement).
Strong paper trail and admissions (HR verified video; HR acknowledged the withheld statement).
We can send a clean, indexed PDF packet: timeline, exhibits, HR emails, names, and preservation targets.
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## Current Status (as of Friday, September 26, 2025)
Employer has terminated Curtis for “job abandonment” + “failure to take drug test.”
We dispute both as false pretexts; Curtis was coerced, on leave, and asserting ADA rights.
We delivered a 4-day written notice seeking resolution; no cure; termination followed.
We have counsel options; one major Atlanta firm declined due to capacity only (not case weakness) and urged contacting NELA referrals. We are posting here to connect quickly with a firm ready to engage.
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If you are licensed in Georgia and handle ADA/retaliation/wrongful termination on contingency, please email or very much preferably text.
Kindly include your bar number, link to your firm site, and earliest availability. We can transmit a full packet immediately.
Thank you.
