LaCrese C. Smith v. Ron Neal, et al.

Summary

The court granted defendants’ Rule 12(b)(6) motion to dismiss LaCrese Smith’s Title VII employment discrimination, retaliation, and race- and gender-discrimination claims. The court held that Smith alleged, at most, that the defendants were supervisors, not employers or joint employers, and that individual supervisors are not liable under Title VII. The court denied Smith’s additional motions, including motions for default judgment, sanctions, and leave to add a 42 U.S.C. § 1983 claim, and directed the clerk to close the case.

Holdings

1. The complaint failed to state a Title VII claim against the individual defendants because it did not allege that they were Smith's employers or joint employers, and Title VII does not authorize individual-capacity suits against supervisors.
2. Even if Smith's timely motion were construed as an amendment as a matter of course, the amendment would be futile because its allegation that defendants exercised significant control over her work was conclusory and established, at most, a supervisory relationship.
3. Smith was not entitled to default judgment because defendants had appeared and defended, and failure to receive a filing by mail did not establish the extreme circumstances required for default judgment.
4. Smith could not add a § 1983 claim through a response or later motion, and the proposed amendment would be futile because she alleged only a conclusory assertion that defendants acted under color of law without facts supporting a plausible § 1983 claim.

Questions Presented

1. Whether Smith's Title VII claims against the individual defendants stated a plausible claim when her complaint identified the Indiana State Prison as her employer and alleged no facts establishing that the defendants were her employers or joint employers.
2. Whether Smith's timely motion asserting a joint-employer relationship could be construed as an amendment and, if so, whether the proposed amendment would cure the pleading defect.
3. Whether Smith was entitled to default judgment or other relief because she allegedly did not receive service by mail of defendants' response and notice of attorney withdrawal.
4. Whether Smith could add a 42 U.S.C. § 1983 claim through a later motion or response to the motion to dismiss.

Disposition

dismissed