Aaron Jozsa v. General Motors Company

Summary

The United States District Court for the Eastern District of Michigan adopts a magistrate judge’s Report and Recommendation and grants General Motors Company’s motion to dismiss. The court concludes that the plaintiff’s FMLA claim is untimely and that his Title VII and ADA claims were filed without exhaustion of administrative remedies. The case is dismissed.

Holdings

1. Plaintiff's FMLA claim was untimely because he did not plausibly plead a willful violation that would extend the limitations period from two years to three years.
2. Plaintiff's Title VII and ADA claims were properly dismissed because the face of the complaint showed that he had not exhausted administrative remedies before filing suit.
3. The objection was overruled because it did not clearly identify the portions of the report and recommendation being challenged or provide a sufficient basis for objection.

Questions Presented

1. Whether Plaintiff's objection sufficiently challenged the recommendation to dismiss his FMLA claim as untimely.
2. Whether the submitted documents plausibly demonstrated a willful violation of the FMLA sufficient to invoke the three-year limitations period.
3. Whether Plaintiff's Title VII and ADA claims were subject to dismissal because he failed to exhaust administrative remedies.

Disposition

dismissed