Summary
This memorandum and order from the United States District Court for the Eastern District of Missouri dismisses a pro se plaintiff's employment discrimination complaint against the United States Postal Service. The court finds that the Americans with Disabilities Act does not apply to the federal government, requiring claims to proceed under the Rehabilitation Act instead. Furthermore, the plaintiff failed to allege sufficient facts to establish plausible elements of disability discrimination or retaliation. Consequently, the complaint is dismissed without prejudice, and the motion to appoint counsel is denied as moot.
Topics
Practice areas
Questions Presented
- Whether Carpenter could pursue an employment-discrimination claim against the United States Postal Service under the Americans with Disabilities Act.
- Whether the complaint, as supplemented by Carpenter's show-cause response, stated a plausible employment-discrimination claim under the Rehabilitation Act.
- Whether the complaint should be dismissed without prejudice for failure to state a claim upon which relief may be granted.
Holdings
- A former federal employee may not bring a separate ADA employment-discrimination claim because the ADA's definition of employer excludes the United States.
- The complaint failed to state a plausible Rehabilitation Act claim because Carpenter alleged no facts showing that he was disabled, otherwise qualified, or discriminated against solely because of his disability.
- The complaint was dismissed without prejudice for failure to state a claim upon which relief may be granted.
Key quotations
“The ADA specifically excludes the United States from its definition of “employer.”” (at 2)
“Because the Court finds plaintiff has not stated a plausible claim of employment discrimination, it will dismiss plaintiff’s complaint.” (at 3)
Factual background
Carpenter was employed by the United States Postal Service and alleged that he suffered injuries in a fall at work. He asserted that management failed to respond properly to the incident and failed to follow appropriate protocols and procedures. He also stated that he was later fired for being absent without leave and for failing to respond to pre-disciplinary interview notices, but he alleged no facts connecting those events to disability discrimination.
Procedural history
Carpenter filed an employment-discrimination complaint alleging that the United States Postal Service discriminated against him because of a disability. The complaint alleged no essential facts, so the court issued a show-cause order requiring him to explain why the action should not be dismissed. Carpenter responded that he was injured in a workplace fall and that management failed to follow proper procedures, and he submitted workers' compensation documents. The court dismissed the complaint without prejudice for failure to state a plausible claim and denied the motion to appoint counsel as moot.