Tia Gooden v. Teamsters Local 705, et al.

Summary

The United States District Court for the Northern District of Illinois granted Teamsters Local 705’s motion to dismiss Counts III and IV of Tia Gooden’s complaint. The court held that the plaintiff failed to allege sufficient factual matter supporting her claims for race discrimination and retaliation under 42 U.S.C. § 1981.

Holdings

1. Gooden failed to state a § 1981 race-discrimination claim because she did not identify a collective bargaining agreement containing an applicable nondiscrimination clause and, even assuming such an agreement existed, offered only a conclusory allegation that similarly situated non-African American employees were treated differently.
2. Gooden failed to state a § 1981 retaliation claim because she did not allege sufficient facts showing that Teamsters refused to process her grievances because of her race or because of earlier complaints about race.

Questions Presented

1. Whether Gooden stated a claim for race discrimination under 42 U.S.C. § 1981 against Teamsters Local 705.
2. Whether Gooden stated a claim for retaliation under 42 U.S.C. § 1981 based on Teamsters' handling of her grievances.

Disposition

dismissed