Cassandra Broussard v. START Corporation

Summary

The United States District Court for the Eastern District of Louisiana granted START Corporation’s partial motion to dismiss claims arising from Cassandra Broussard’s employment termination and alleged workplace discrimination. The court dismissed the Louisiana Employment Discrimination Law claim with prejudice because START Corporation was alleged to be a nonprofit, dismissed the intentional infliction of emotional distress claim without prejudice, and dismissed the negligent supervision claim with prejudice under the Louisiana Workers’ Compensation Act.

Holdings

1. A nonprofit corporation is excluded from the Louisiana Employment Discrimination Law's definition of employer, so Broussard failed to state a claim under that statute.
2. Broussard failed to state a Louisiana intentional-infliction-of-emotional-distress claim because the alleged workplace discrimination, hostile work environment, bullying, and harassment did not sufficiently allege extreme and outrageous conduct or severe emotional distress.
3. The Louisiana Workers' Compensation Act barred Broussard's negligent-supervision claim because she did not allege a qualifying intentional act.

Questions Presented

1. Whether Broussard stated a claim under the Louisiana Employment Discrimination Law where she alleged that START Corporation was a nonprofit corporation.
2. Whether Broussard adequately pleaded intentional infliction of emotional distress under Louisiana law.
3. Whether the Louisiana Workers' Compensation Act barred Broussard's negligent-supervision claim absent allegations of an intentional act.

Disposition

other