Alake Gbohunmi and Stephanie Keene v. Momentum Advisory Collective

Summary

The United States District Court for the Eastern District of Pennsylvania dismissed with prejudice Alake Gbohunmi’s claim for retaliation under 42 U.S.C. § 1981, holding that she did not plausibly allege objectively reasonable protected activity. The court declined to exercise supplemental jurisdiction over Stephanie Keene’s Pennsylvania Human Relations Act claims and dismissed the entire action with prejudice.

Holdings

1. A plaintiff asserting retaliation under § 1981 must plausibly allege that she engaged in protected activity by acting under a good-faith, objectively reasonable belief that the employer engaged in unlawful race discrimination. General complaints of unfair treatment, unsupported assertions of retaliation or hostility, and conduct not connected to race do not satisfy this requirement.
2. The amended complaint failed to state a plausible § 1981 retaliation claim because it did not adequately plead protected activity.
3. Further amendment would be futile, so the court dismissed Gbohunmi's § 1981 retaliation claim with prejudice.
4. After dismissing the only federal claim, the court declined to exercise supplemental jurisdiction over Keene's remaining PHRA claims.

Questions Presented

1. Whether Gbohunmi plausibly alleged that she engaged in protected activity under 42 U.S.C. § 1981 by reporting conduct based on an objectively reasonable, good-faith belief that the conduct constituted race discrimination.
2. Whether Gbohunmi's amended complaint plausibly alleged a § 1981 retaliation claim.
3. Whether the court should grant further leave to amend Gbohunmi's claim.
4. Whether the court should exercise supplemental jurisdiction over Keene's remaining PHRA claims after dismissing the federal claim.

Disposition

dismissed