Sabrina Franklin v. Stellantis Chrysler, UAW Solidarity House, Paul Ludka, Joe Nue, and Peter Raith

Summary

The United States District Court for the Eastern District of Wisconsin screens Sabrina Franklin’s pro se Title VII complaint alleging race- and color-based discrimination arising from a delayed promotion and training process. The court dismisses the individual defendants because Title VII does not provide for individual liability and concludes that the complaint does not plausibly connect the alleged failure to promote to race or color discrimination. The court permits Franklin to file an amended complaint by January 30, 2026, or the case will be dismissed without prejudice.

Holdings

1. Title VII does not provide for individual liability; only an employer may be held liable under Title VII. Accordingly, the claims against Paul Ludka, Joe Nue, and Peter Raith could not proceed under Title VII.
2. The complaint failed to state a plausible Title VII claim against FCA US LLC or UAW Solidarity House because it did not explain which entity controlled the position or promotion, how each defendant was involved, or why the failure to promote was connected to Franklin's race or color rather than another reason.
3. The complaint appeared to satisfy Title VII's administrative-exhaustion and filing-timeliness requirements because Franklin alleged that she filed an EEOC charge, received a right-to-sue letter, and filed suit within the ninety-day period specified in the letter.
4. Because the deficiencies might be cured by providing additional factual detail, the plaintiff was entitled to an opportunity to file an amended complaint before the action was dismissed.

Questions Presented

1. Whether the complaint stated a plausible Title VII employment-discrimination claim against FCA US LLC and UAW Solidarity House.
2. Whether Paul Ludka, Joe Nue, and Peter Raith could be held individually liable under Title VII.
3. Whether the plaintiff should be permitted to amend the deficient complaint rather than have the action immediately dismissed.

Disposition

other