Brent Jason v. Adobe, Inc. and Does 1-10

Summary

The United States District Court for the District of Oregon granted Adobe, Inc.’s motion to dismiss Brent Jason’s second amended complaint. The court held that Jason failed to adequately plead diversity jurisdiction and failed to state viable claims for breach of contract, disability discrimination, or retaliation, while several claims were time-barred. The action was dismissed with prejudice and without leave to amend.

Holdings

1. The second amended complaint failed to establish diversity jurisdiction because it did not affirmatively allege the citizenship of plaintiff and Adobe or facts showing that the amount in controversy exceeded $75,000.
2. The retaliation claim under Oregon Revised Statutes § 659A.109 was time-barred because it was subject to a one-year limitations period and was filed more than one year after plaintiff's alleged termination.
3. The breach-of-contract claims failed because plaintiff did not identify the relevant contractual terms, allege full performance of his obligations, or adequately allege defendant's breach and resulting damages.
4. The disability-discrimination claim under Oregon Revised Statutes § 659A.112 failed because plaintiff did not allege that his attention deficit disorder substantially interfered with a major life activity, that the adverse employment action was causally connected to the disability, or that he could perform the essential functions of his job with or without reasonable accommodation.
5. Further amendment would be futile, so dismissal was properly entered with prejudice and without leave to amend.

Questions Presented

1. Whether the second amended complaint adequately pleaded diversity jurisdiction under 28 U.S.C. § 1332.
2. Whether the second amended complaint stated plausible claims for relief under Federal Rule of Civil Procedure 12(b)(6).
3. Whether the alleged retaliation claim was barred by the applicable statute of limitations.
4. Whether the alleged breach-of-contract claims pleaded the existence and relevant terms of a contract, plaintiff's performance, defendant's breach, and resulting damages.
5. Whether the alleged Oregon disability-discrimination claim pleaded a qualifying disability, a causal connection between the disability and an adverse employment action, and the ability to perform essential job functions with or without reasonable accommodation.
6. Whether further amendment would be futile and dismissal should therefore be with prejudice and without leave to amend.

Disposition

dismissed