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The Robert J. Dole Federal Courthouse for the District of Kansas

A former employee of the Willow Domestic Violence Center has filed a lawsuit in federal court, alleging that the nonprofit failed to pay her and others overtime wages, retaliated against her and wrongfully fired her.

According to the complaint filed Oct. 11 in the U.S. District Court of Kansas in Kansas City, Kan., Maggie Reynolds was a program coordinator at The Willow’s Ottawa facility until she was fired on April 18. Her start date is not clear from the documents.

The suit says a supervisor told Reynolds and another program coordinator that beginning in January, they were no longer permitted to work more than 40 hours per week. However, the complaint says it was necessary for Reynolds to continue working between 60 and 80 hours per week to provide quality services to her clients.

In mid-February, the suit says, the supervisor told Reynolds she must immediately begin taking 80 hours of “flex time” — time off work for which she would be paid at her regular rate, rather than being paid for the time she had worked in excess of 40 hours per week.

The suit says Reynolds agreed to use the flex time on Tuesdays and Thursdays; however, because her caseload was too heavy, she needed to work from home or from the office on those days. The suit says Reynolds had regularly communicated to her supervisor that the workload was too heavy and another program coordinator position was needed.

Sometime before she was fired, the suit says, Reynolds “sent a communication to her supervisor expressly indicating that she was no longer going to accurately complete her timecards to reflect all the hours she was working because she felt like she was being reprimanded for being honest.”

Reynolds was fired shortly thereafter. She was told the reason was her “having a negative attitude” and turning in paperwork late, the suit says; the suit claims her only negative statements about her work were regarding her heavy workload and that she was not being paid for the time she was working.

The suit says in one count that The Willow willfully failed to pay Reynolds time and a half for hours beyond 40 per week. It requests judgment for economic damages, back pay, liquidated damages, reasonable attorneys’ fees and costs incurred, pre- and post-judgment interest and other equitable relief the court deems proper.

In a second count, the suit says Reynolds’ “good faith complaint of The Willow’s unlawful conduct” in violation of the Fair Labor Standards Act was a determining factor in her termination. It says she suffered intentional discrimination because of her report, and that she has suffered humiliation, mental anguish, pain and a loss of self-esteem, as well as being deprived of income and benefits.

“… The Willow’s conduct was willful, wanton, and malicious, and showed complete indifference to or conscious disregard for the rights of others, … thus justifying an award of punitive damages in an amount sufficient to punish The Willow or to deter it and other employers from like conduct in the future,” the complaint says.

In the alternative, the suit alleges similar overtime pay problems but for Reynolds’ work in excess of 46 hours per week, in line with the Kansas Minimum Wage and Maximum Hours Law. It also says The Willow appreciated the benefit of her work but she was not paid her anticipated wages, and therefore requests restitution in the value of anticipated but unpaid wages.

The lawsuit requests a jury trial in Kansas City, Kan. The case has been assigned to District Judge John W. Lungstrum and Magistrate Judge Kenneth G. Gale, according to online court records.

Will Averill, The Willow’s director of communications, said via email Thursday morning that the center couldn’t comment on an open case at this time.

In an automated email response to the Journal-World’s request for further comment Thursday, Joshua Wunderlich, Reynolds’ Kansas City, Mo.-based attorney, said he was out of office this week.