Jimmy Keels Williamson v. Christian Recovery Centers, Inc.

Summary

The United States District Court for the Eastern District of North Carolina adopted a magistrate judge’s recommendation concerning screening of a pro se complaint under 28 U.S.C. § 1915(e). The court dismissed without prejudice the plaintiff’s Title VII, ADA, and FHA disability-discrimination claims for failure to state a claim, while allowing the FHA racial-discrimination claim to proceed.

Holdings

1. When no objections are filed to a magistrate judge's memorandum and recommendation, the district court reviews the magistrate judge's findings and conclusions for clear error and may adopt the recommendation without providing an explanation.
2. The court dismissed plaintiff's Title VII race-discrimination and hostile-work-environment claims, ADA disability-discrimination claim, and FHA disability-discrimination claim without prejudice for failure to state a claim upon which relief can be granted.
3. Plaintiff's FHA housing-discrimination claim based on race was allowed to proceed.

Questions Presented

1. Whether the district court should review the unobjected-to memorandum and recommendation for clear error and adopt it.
2. Whether plaintiff's Title VII race-discrimination and hostile-work-environment claims, ADA disability-discrimination claim, and FHA disability-discrimination claim should be dismissed under 28 U.S.C. § 1915(e)(2)(B) for failure to state a claim.
3. Whether plaintiff's FHA racial-discrimination claim could proceed beyond initial screening.

Disposition

other