Tammi Roberson v. Aramark and Matt Hubacher

Summary

The United States District Court for the Eastern District of Wisconsin screened Tammi Roberson’s first amended complaint alleging employment discrimination, harassment, retaliation, and related misconduct by Aramark and Matt Hubacher. The court held that the complaint did not plausibly connect the alleged adverse actions to a protected characteristic under Title VII or the Americans with Disabilities Act and was not complete as required. The court granted Roberson until April 27, 2026, to file a second amended complaint, warning that failure to do so could result in a recommendation of dismissal.

Holdings

1. The amended complaint failed to state a Title VII claim because it did not allege facts plausibly connecting Roberson's termination or other adverse treatment to a protected characteristic.
2. The amended complaint failed to state an ADA discrimination claim because Roberson did not allege that she was a qualified person with a disability or that anyone treated her differently because of an ADA-protected characteristic.
3. The amended complaint did not comply with the requirement that it be complete in itself and state all allegations and requested relief without reference to the original complaint.
4. When screening under 28 U.S.C. § 1915(e)(2)(B)(ii), the court applies the same standards used for a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6).

Questions Presented

1. Whether the first amended complaint stated a claim for employment discrimination under Title VII.
2. Whether the first amended complaint stated a claim for disability discrimination under the Americans with Disabilities Act.
3. Whether the amended complaint complied with the requirement that it be complete in itself and replace the original complaint without reference to it.

Disposition

other