Redd-Oyedele v. Santa Clara County Office of Education

Summary

The United States District Court for the Northern District of California partially granted and partially denied defendants’ motion to dismiss an employment discrimination action brought under Title VII, the Fourteenth Amendment, FEHA, 42 U.S.C. § 1983, and 42 U.S.C. § 1985(3). The court dismissed the FEHA claim against the Santa Clara County Office of Education with prejudice on Eleventh Amendment immunity grounds, while allowing the other claims to proceed. The court terminated the motion to strike as moot.

Holdings

1. The Second Amended Complaint sufficiently alleged an ongoing violation of federal law and sought prospective injunctive relief, so the Ex parte Young exception permitted the official-capacity claims in counts two, four, and five to proceed past the pleading stage.
2. The FEHA claim against the Santa Clara County Office of Education was barred by Eleventh Amendment immunity because California had not waived its immunity to FEHA suits in federal court.
3. The Second Amended Complaint adequately pleaded conspiracy claims under 42 U.S.C. §§ 1983 and 1985(3), and counts four and five survived the motion to dismiss.

Questions Presented

1. Whether the Second Amended Complaint sufficiently alleged ongoing violations of federal law and prospective relief to invoke the Ex parte Young exception to Eleventh Amendment immunity against the individual defendants in their official capacities.
2. Whether California's Eleventh Amendment immunity barred Plaintiff's FEHA claim against the Santa Clara County Office of Education in federal court.
3. Whether the Second Amended Complaint adequately pleaded conspiracy claims under 42 U.S.C. §§ 1983 and 1985(3).
4. Whether the motion to strike the newly added FEHA count should be decided after that count was dismissed.

Disposition

other