Joy Orji v. Walmart Superstores, Inc.

Summary

The United States District Court for the Eastern District of California reviewed objections to a magistrate judge’s findings and recommendations concerning dismissal of Joy Orji’s claims against Walmart Superstores, Inc. The court dismissed the false-imprisonment claim without leave to amend, but denied dismissal of claims under 42 U.S.C. § 1981 and California’s Unruh Civil Rights Act. The court also denied Walmart’s motion to strike and referred the matter back to the magistrate judge for further pretrial proceedings.

Holdings

1. Plaintiff plausibly stated a § 1981 claim by alleging that Walmart employees subjected her to racial discrimination while she was attempting to contract with Walmart. A retail customer need not allege that she was completely prevented from making a purchase when the alleged discrimination occurred during the formation, performance, modification, or enjoyment of the contractual relationship.
2. Plaintiff plausibly stated a claim for intentional racial discrimination under the Unruh Civil Rights Act. She was not required at the pleading stage to allege or prove that she was treated differently from a specific white customer, and the fact that she ultimately received the items did not preclude the claim.
3. Plaintiff failed to state a claim for false imprisonment.
4. The motion to strike was denied because striking Plaintiff's requests for relief was improper.

Questions Presented

1. Whether Plaintiff plausibly alleged that Walmart discriminated against her on the basis of race in the making, performance, modification, or enforcement of a contractual relationship under 42 U.S.C. § 1981.
2. Whether Plaintiff plausibly alleged intentional racial discrimination and denial of full and equal privileges or services under California's Unruh Civil Rights Act.
3. Whether Plaintiff stated a claim for false imprisonment.
4. Whether portions of Plaintiff's requested relief should be stricken.

Disposition

other