Samantha D. Rajapakse v. Clarence H. Carter, Commissioner of Tennessee Department of Human Services, et al.

Summary

The United States District Court for the Middle District of Tennessee grants Samantha D. Rajapakse leave to proceed in forma pauperis and conducts the required initial review of her civil-rights complaint. The court allows her ADA discrimination and retaliation claims against the Tennessee Department of Human Services and its commissioner to proceed, including claims involving her termination, an unresolved EEOC conciliation agreement, disability-benefit proceedings, and vocational rehabilitation. The court also grants her motion to supplement the complaint, directs service, and refers the action for further proceedings.

Holdings

1. Plaintiff may proceed in forma pauperis because her financial disclosures support the finding that she cannot pay the civil filing fee without undue hardship.
2. The motion to supplement the complaint is granted insofar as it seeks to add events occurring after the original complaint.
3. The complaint and supplement sufficiently plead ADA discrimination and retaliation claims to survive initial review and proceed for further development of the record.
4. Plaintiff's request for partial summary judgment is denied because the case is at an early stage and requires further development of the record.
5. The action is not dismissed at initial screening because Plaintiff's allegations are sufficiently pleaded.

Questions Presented

1. Whether Rajapakse qualified to proceed in forma pauperis under 28 U.S.C. § 1915(a).
2. Whether the motion to supplement the complaint was proper under Federal Rule of Civil Procedure 15(d).
3. Whether the complaint and supplemental allegations stated plausible ADA discrimination and retaliation claims sufficient to survive initial screening under 28 U.S.C. § 1915(e)(2)(B).
4. Whether the court could award partial summary judgment at the early stage of the proceedings.

Disposition

other