Summary
Pro se plaintiff's ADA disability discrimination claim survived a motion to dismiss where he alleged termination for job abandonment while hospitalized for diabetes ketoacidosis, and that his employer knew of his condition. The district court held that under Rule 8(a) and *Swierkiewicz v. Sorema*, a plaintiff need not plead a *prima facie* case of discrimination; a short and plain statement providing fair notice of the claim is sufficient. The defendant's motion was denied without prejudice, with the court emphasizing that pro se complaints are liberally construed and that allegations of disability, employer notice, and termination due to the disability state a plausible ADA claim.
Holdings
- A plaintiff's employment discrimination complaint need not allege specific facts establishing a prima facie case of discrimination; it need only provide a short and plain statement of the claim sufficient to put the defendant on notice.
Questions Presented
- Whether the complaint states a claim for disability discrimination under the ADA.
Disposition
other
Cases Cited (13)
- Swierkiewicz v. Sorema N.A., 534 U.S. 506 (2002)(positive)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007)(positive)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009)(positive)
- Conley v. Gibson, 355 U.S. 41 (1957)(positive)
- Erickson v. Pardus, 551 U.S. 89 (2007)(positive)
- Papasan v. Allain, 478 U.S. 265 (1986)(positive)
- In re United Mine Workers of Am. Employee Benefit Plans Litig., 854 F. Supp. 914 (D.D.C. 1994)(positive)
- Schuler v. United States, 617 F.2d 605 (D.C. Cir. 1979)(positive)
- Haines v. Kerner, 404 U.S. 519 (1972)(positive)
- EEOC v. St. Francis Xavier Parochial Sch., 117 F.3d 621 (D.C. Cir. 1997)(positive)
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Court Document
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