Calvin Ellis Mance v. AutoZoners LLC, et al.

Summary

The United States District Court for the Northern District of Indiana granted AutoZoners LLC and Tracy E. Kern’s motion to dismiss claims for defamation, Title VII hostile work environment and retaliation, and intentional infliction of emotional distress. The court also denied the plaintiff’s motions for a stay and default judgment. The complaint was dismissed without prejudice, with leave to amend by June 9, 2026.

Holdings

1. Statements made in the EEOC proceeding were absolutely privileged and could not support a defamation claim against Kern or AutoZone.
2. Mance failed to state a viable defamation claim based on Rottinghaus's email because the complaint did not plausibly allege facts overcoming the qualified privilege for intracompany communications.
3. Mance failed to state a hostile-work-environment claim because he alleged only a conclusory assertion of race-based bullying and harassment and did not allege exhaustion of administrative remedies.
4. Mance failed to state a Title VII retaliation claim under either the direct or indirect method.
5. Mance failed to state an Indiana intentional-infliction-of-emotional-distress claim because the alleged conduct was not extreme and outrageous and the complaint did not plausibly allege that defendants intentionally caused the asserted injury.
6. Mance was not entitled to default judgment because defendants timely moved to dismiss by the applicable deadline.

Questions Presented

1. Whether Mance plausibly stated a defamation claim based on Rottinghaus's internal email, Kern's EEOC position statement, or alleged community knowledge of his termination.
2. Whether Mance plausibly stated a Title VII hostile-work-environment claim and exhausted his administrative remedies.
3. Whether Mance plausibly stated a Title VII retaliation claim under either the direct or indirect method.
4. Whether Mance plausibly stated an Indiana intentional-infliction-of-emotional-distress claim.
5. Whether Mance was entitled to a stay or default judgment against defendants.

Disposition

other