Aaron Michael Stricklin v. Amazon.com Services LLC

Summary

The United States District Court for the Eastern District of Arkansas grants Amazon.com Services LLC’s partial motion to dismiss an ADA association-discrimination claim brought by former employee Aaron Michael Stricklin. The court holds that EEOC charges may be considered without converting the motion into one for summary judgment and concludes that Stricklin failed to exhaust the association-discrimination claim because his charges addressed only his own disability and accommodation requests. Claim IV of the amended complaint is dismissed with prejudice.

Holdings

1. The court could consider the EEOC charges because they were public records and were incorporated by reference into, and integral to, the amended complaint.
2. Stricklin failed to exhaust his ADA association-discrimination claim because neither EEOC charge alleged that he suffered discrimination because of his partner's disability; the claim was therefore dismissed with prejudice.
3. Liberal pleading standards for pro se litigants did not excuse the failure to exhaust the distinct ADA association-discrimination claim.

Questions Presented

1. Whether the court could consider Stricklin's EEOC charges on a Rule 12 motion without converting the motion into one for summary judgment.
2. Whether Stricklin exhausted an ADA association-discrimination claim when neither EEOC charge alleged discrimination based on his partner's disability.
3. Whether liberal pleading standards for a pro se litigant allowed the unexhausted association-discrimination claim to proceed.

Disposition

dismissed