Deborah Davis v. The Advanced Composite Center, et al.

Summary

The United States District Court for the Eastern District of Missouri grants Deborah Davis’s application to proceed in forma pauperis but dismisses her employment-discrimination complaint without prejudice under 28 U.S.C. § 1915(e)(2)(B). The court concludes that Davis failed to plead sufficient facts supporting Title VII discrimination or retaliation, including facts showing disparate treatment or a causal connection to protected activity. The court also dismisses her ADA claim because she did not identify a qualifying disability or allege discrimination based on disability.

Holdings

1. The amended complaint failed to state a Title VII discrimination claim because it did not allege facts showing that Plaintiff was treated adversely because of membership in a Title VII protected class, including facts concerning qualification, disparate treatment, or more favorable treatment of similarly situated employees outside the protected class.
2. The amended complaint failed to state a Title VII retaliation claim because it did not adequately allege protected conduct and did not allege a causal link between Plaintiff's prior EEOC complaint or other protected activity and the alleged adverse employment actions.
3. The amended complaint failed to state an ADA discrimination claim because Plaintiff did not allege that she had a disability cognizable under the ADA or that an adverse employment action occurred because of such a disability.
4. The Court was required to dismiss the action without prejudice under 28 U.S.C. § 1915(e)(2)(B) because the amended complaint failed to state a claim under Title VII or the ADA.

Questions Presented

1. Whether Plaintiff's amended complaint stated a plausible Title VII discrimination claim.
2. Whether Plaintiff's amended complaint stated a plausible Title VII retaliation claim.
3. Whether Plaintiff's amended complaint stated a plausible ADA disability-discrimination claim.
4. Whether the action was subject to dismissal during in forma pauperis screening under 28 U.S.C. § 1915(e)(2).

Disposition

dismissed