EEOC Charge of Discrimination and Retaliation – Thomas D. Coates v. Cox Communications & MetLife

I. PARTIES AND JURISDICTION

Complainant: Thomas D. Coates
Respondent 1: Cox Communications, Inc. (Employer)
Respondent 2: MetLife (Third-Party Disability Claims Administrator for Cox)

This charge is timely filed and alleges violations of the Americans with Disabilities Act (ADA), Title VII of the Civil Rights Act, and the Family and Medical Leave Act (FMLA). Jurisdiction is proper as the most recent adverse action occurred on April 30, 2025 and involved both Cox and MetLife.

II. SUMMARY OF FACTS AND RECENT VIOLATIONS

I was employed by Cox Communications, Inc. and was eligible for short-term disability benefits administered by MetLife.
In 2024 and 2025, I made multiple timely requests for leave and accommodation due to a family medical crisis. These requests were processed, at least in part, by MetLife as Cox’s designated third-party administrator.
On or about April 30, 2025, I received official correspondence from the Virginia Employment Commission (VEC) and/or MetLife regarding my claim status, which referenced information provided by Cox and/or MetLife about my payroll and the circumstances of my termination.
The Equal Employment Opportunity Commission (EEOC) recently denied my prior charge based on incomplete and/or false information supplied by Cox and/or MetLife, specifically regarding the timing and reasons for my termination and my eligibility for disability benefits.
The information provided by Cox and MetLife to the EEOC and VEC was materially false or incomplete, directly impacting my rights and eligibility for both employment and disability benefits, and constitutes a new and continuing violation.
The most recent denial and adverse action occurred within the last 30 days, making this charge timely and based on new facts and parties not previously investigated.

III. STATUTORY AND REGULATORY VIOLATIONS

Violation of ADA, 42 U.S.C. § 12112(a) and (b)(4) – associational disability discrimination and retaliation.
Violation of FMLA, 29 U.S.C. § 2615 – interference and retaliation regarding protected leave.
Violation of Title VII, 42 U.S.C. § 2000e-3(a) – retaliation for protected activity.
Violation of EEOC regulations, 29 C.F.R. § 1601.15(c), § 1601.18 – submission of false/incomplete information to the EEOC.
Violation of state law and public policy regarding truthful reporting to VEC and disability administrators.

IV. RELIEF AND REMEDIES SOUGHT

Immediate investigation of Cox and MetLife for providing false or incomplete information to the EEOC and VEC.
Restoration of my employment status and/or disability benefits as appropriate.
Corrective action against Cox and MetLife for retaliation, discrimination, and interference with my rights.
Referral to DOJ, DOL, and state agencies for coordinated enforcement and oversight.
Any other relief deemed just and proper by the Commission.

V. MOST RECENT ADVERSE ACTION (FOR TIMELINESS)

"Wed, Apr 30, 8:27 AM: Correspondence or a request for information is now available for you to view or complete in Claimant Self-Service. Use the smart link below to access or establish your online account. https://uidirect.vec.virginia.gov/CSS"

This correspondence was based on information provided by Cox and/or MetLife, which is the subject of this charge.

VI. EXHIBITS AND EVIDENCE

Copy of VEC/MetLife correspondence dated April 30, 2025.
Prior EEOC closure letter and Cox/MetLife position statements.
Documentation of all prior accommodation and leave requests.
Any additional evidence of false or incomplete reporting by Cox or MetLife.

VII. SERVICE AND NOTICE TO THIRD PARTIES

EEOC Norfolk Area Office
MetLife Disability Claims Department
Cox Communications, Inc. HR and Legal
Virginia Employment Commission (VEC)
U.S. Department of Justice, Civil Rights Division
U.S. Department of Labor, Wage and Hour Division
Other relevant state and federal oversight agencies

Notice: This charge is intended to satisfy the recordkeeping, disclosure, and transmission requirements of all referenced agencies and courts. All parties are requested to preserve, review, and incorporate this record in accordance with applicable law.