Maurice Smith-Davis v. Michigan Department of Corrections, et al.

Summary

The United States District Court for the Eastern District of Michigan granted Defendants’ motion to dismiss Maurice Smith-Davis’s claims under the ADA, FMLA, 42 U.S.C. § 1983, Title VII, and the Michigan Elliott-Larsen Civil Rights Act. The court held that certain claims were barred by sovereign immunity and that the remaining claims lacked sufficient factual detail to state plausible claims for relief. The court also granted Plaintiff’s motion for leave to file a sur-reply but denied any request to amend or supplement the complaint.

Holdings

1. Title I ADA claims for money damages against a State or state agency, and against state employees sued in their official capacities, are barred by Eleventh Amendment sovereign immunity.
2. A plaintiff seeking prospective injunctive relief under Ex parte Young must allege facts connecting the state official sued in an official capacity to the continuing violation; generalized allegations that defendants acted in supervisory roles are insufficient.
3. Eleventh Amendment immunity bars money-damages claims against a State or its agencies under the FMLA self-care provision, but does not bar such claims under the FMLA family-care provision.
4. An FMLA retaliation claim is insufficiently pleaded when the plaintiff does not identify the retaliatory acts, when they occurred, or who took them; the FMLA does not itself provide an entitlement to paid leave.
5. A damages claim against government officials under § 1983 must allege with particularity what each defendant did to violate the asserted constitutional right; collective allegations against multiple defendants are insufficient.
6. Title VII actions may not be brought against employees or supervisors in their individual capacities when they are not alleged to be employers.
7. A Title VII retaliation complaint must plead facts plausibly showing protected activity and retaliatory conduct; allegations concerning disability discrimination are not protected activity under Title VII, and broad conclusory allegations concerning religious discrimination are insufficient.
8. MDOC, as a Michigan state agency, is immune from private ELCRA suits in federal court absent waiver or valid abrogation, and ELCRA does not prohibit disability discrimination.
9. A party may not amend a complaint through a sur-reply, and leave to amend or supplement may be denied when the proposed amendment is not provided and therefore does not give the opposing party notice of its contents.

Questions Presented

1. Whether Plaintiff's ADA damages claims against MDOC and individual defendants sued in their official capacities are barred by Eleventh Amendment sovereign immunity.
2. Whether Plaintiff adequately stated an ADA claim for prospective injunctive relief against individual defendants in their official capacities.
3. Whether sovereign immunity barred Plaintiff's FMLA claims and, if not, whether the claims were pleaded plausibly.
4. Whether Plaintiff adequately pleaded a 42 U.S.C. § 1983 claim against the individual defendants in their personal capacities.
5. Whether Plaintiff could maintain a Title VII retaliation claim against individual supervisors and whether his allegations against MDOC were sufficient.
6. Whether Plaintiff could maintain his Michigan Elliott-Larsen Civil Rights Act claims against MDOC and the individual defendants.
7. Whether Plaintiff should be granted leave to file a sur-reply or to amend or supplement his complaint through that filing.

Disposition

dismissed