Demetrius Sloan v. Hammond Dual Hotels LLC, et al.

Summary

The United States District Court for the Northern District of Indiana denied Demetrius Sloan’s motion to proceed in forma pauperis because his complaint did not establish subject matter jurisdiction. The court concluded that Sloan had not exhausted administrative remedies for his Title VII claims and had not adequately pleaded federal-question or diversity jurisdiction for his state-law claims. The court granted leave to amend and refile by April 24, 2026, warning that failure to comply could result in dismissal.

Holdings

1. A plaintiff must exhaust Title VII administrative remedies by filing charges with the EEOC and receiving a right-to-sue letter before bringing a Title VII action in federal court; because Sloan did not attach the required documents or otherwise establish exhaustion, the court lacked subject matter jurisdiction over his Title VII claims.
2. The Indiana civil-rights claim did not establish federal-question jurisdiction because it arose under Indiana law, and it could not proceed under supplemental jurisdiction absent a valid federal claim.
3. The complaint did not establish diversity jurisdiction over the defamation claim because it alleged that both Sloan and Hammond Dual Hotels LLC were Indiana citizens, defeating complete diversity.
4. The motion to proceed in forma pauperis was denied because the complaint failed to establish subject matter jurisdiction and did not state a viable claim within the court's jurisdiction.

Questions Presented

1. Whether Sloan's complaint established federal-question jurisdiction over his Title VII discrimination and retaliation claims despite failing to allege exhaustion of administrative remedies.
2. Whether the Indiana civil-rights claim established federal-question jurisdiction or could proceed through supplemental jurisdiction.
3. Whether the defamation claim established diversity jurisdiction when the complaint alleged that both Sloan and Hammond Dual Hotels LLC were Indiana citizens.
4. Whether Sloan's motion to proceed in forma pauperis should be granted when the complaint failed to establish subject matter jurisdiction.

Disposition

other