Alonzo C. DeCarlo v. Lincoln Land Community College

Summary

The United States District Court for the Central District of Illinois considered Lincoln Land Community College’s motion to dismiss Alonzo C. DeCarlo’s First Amended Complaint alleging race discrimination and retaliation under Title VII. The court found that the complaint adequately pleaded race discrimination and retaliation based on the denial of tenure, but lacked allegations concerning exhaustion of administrative remedies and did not adequately plead constructive discharge. The court dismissed the First Amended Complaint without prejudice and granted DeCarlo 21 days to file a Second Amended Complaint.

Holdings

1. The First Amended Complaint was deficient because it did not allege that Plaintiff filed a charge with the EEOC or received a right-to-sue letter. Plaintiff was granted leave to amend to allege exhaustion.
2. The complaint plausibly stated a Title VII race-discrimination claim because it alleged that Plaintiff, a Black man, suffered adverse employment actions and identified similarly situated non-Black faculty members who were treated more favorably.
3. The complaint plausibly stated a Title VII retaliation claim based on the alleged denial of tenure after Plaintiff complained to College administrators that he believed he was being treated differently because he was Black.
4. Plaintiff did not adequately allege constructive discharge because the alleged circumstances did not show that termination was imminent and inevitable or that the working conditions were so intolerable that he was forced to quit.

Questions Presented

1. Whether the First Amended Complaint adequately alleged exhaustion of Title VII administrative remedies.
2. Whether the complaint plausibly stated a Title VII race-discrimination claim under Rule 8(a) and Rule 12(b)(6).
3. Whether the complaint plausibly stated a Title VII retaliation claim based on the denial of tenure after Plaintiff complained of racial discrimination.
4. Whether Plaintiff adequately alleged constructive discharge as a materially adverse action.

Disposition

dismissed