Nevada Firefighter Files Race Discrimination, Harassment, and Retaliation Suit
A former Clark County firefighter recruit has filed suit in federal court alleging discrimination, harassment, and retaliation during his probationary period with the Clark County Fire Department. The complaint was filed November 11, 2025, in the U.S. District Court for the District of Nevada by Oscar Pavon, a member of Recruit Class 24-1.
According to the complaint, Pavon began the fire academy on February 5, 2024, as one of 78 recruits. Fifty-eight—including Pavon—graduated on June 20, 2024, and were assigned as probationary firefighters. For approximately five months, the complaint states Pavon received “mostly positive” performance evaluations on both fire and EMS calls and had his probationary task book fully signed off in December 2024.
The complaint describes several incidents beginning in November 2024. Pavon alleges he declined to “shop off shift”—which he characterized as working unpaid outside of scheduled hours—when asked by a senior firefighter. Shortly afterward, he reportedly received threatening text messages from another firefighter stating he did not deserve to be a firefighter and instructing him to “do what you are told.” Members of his probationary class allegedly received similar messages warning them that signing up for overtime was “a dangerous game” that took overtime away from senior employees.
Pavon asserts that after he signed up for overtime, his schedule was abruptly changed and he was transferred out of his original station—where he states he had strong performance reviews—to Station 18. He describes Station 18 as a hostile environment where he was assigned as a “fifth man” on an engine normally staffed with four personnel.
The complaint further alleges that one day Pavon became ill on a shift and notified his battalion chief that he intended to finish the shift. Thereafter, he claims he rested in the dorm. When his symptoms worsened, he used sick leave for his next three scheduled shifts. He indicates those absences were documented, including written evaluations from the day he became ill. Despite this, Pavon contends he was criticized for “sleeping at the station” and questioned about his overtime sign-ups after his return from sick leave.
Following his transfer, Pavon alleges he began receiving negative evaluations from multiple captains over roughly ten shifts. He claims that similarly situated Caucasian probationary firefighters at Station 18 were not evaluated on every shift, contrary to department policy. He also contends that on a traumatic overtime call involving deceased children, he was denied an evaluation despite requesting one.
The complaint states that another probationary firefighter, identified as African American, also stopped receiving required evaluations after completing 40 shifts, which Pavon cites as evidence of selective enforcement.
According to the filing, on January 30, 2025, Pavon was called into a meeting with Fire Chief Billy Samuels, Battalion Chief Kenneth Holding, Senior Deputy Chief Thomas Touchstone, his union representative, and an armed individual. Pavon alleges he was told it would be his last day. When he questioned the decision, Chief Samuels allegedly referenced his evaluations and commented about “sleeping,” which Pavon maintains referred to the day he was ill.
Pavon states he was given a choice to resign voluntarily or face involuntary termination. He alleges that Battalion Chief Holding encouraged him to resign, saying it would not affect future employment. The complaint states that five minority recruits—two African American, two Hispanic (including Pavon), and one Asian—were forced to resign under similar circumstances.
The suit brings six causes of action:
- Race discrimination under Title VII
- Hostile environment racial harassment under Title VII
- Retaliation under Title VII
- Race discrimination under 42 U.S.C. § 1981
- Hostile environment racial harassment under § 1981
- Retaliation under § 1981
Pavon seeks back pay, front pay, compensatory damages, punitive damages, attorney’s fees, and other relief. He demands a jury trial. Here is a copy of the complaint.
