Chanelle Dionne Williams v. Saint Francis Hospital, Inc., Candice Robbins, and Randy Flatts

Summary

The United States District Court for the Northern District of Oklahoma granted defendants’ partial motion to dismiss in a pro se employment-discrimination case. The court held that the complaint did not plausibly state a claim under 42 U.S.C. § 1983 because it did not identify a constitutional violation or allege that defendants were state actors. The court dismissed the complaint but allowed the plaintiff to file an amended complaint asserting potentially applicable claims under the Americans with Disabilities Act or Family and Medical Leave Act.

Holdings

1. Plaintiff failed to state a plausible § 1983 claim because she did not allege that defendants violated a federal constitutional right or that any defendant was a state actor.
2. The complaint was properly dismissed for failure to state a claim upon which relief could be granted because its allegations concerning § 1983 were insufficient and conclusory.
3. Plaintiff was permitted to file an amended complaint asserting potentially applicable disability or medical-leave claims in separate counts.

Questions Presented

1. Whether plaintiff stated a claim under 42 U.S.C. § 1983 against the hospital and individual defendants.
2. Whether the complaint should be dismissed when it did not allege a constitutional violation or facts establishing that defendants acted under color of state law.
3. Whether plaintiff should be granted leave to amend to assert potentially applicable disability-discrimination or medical-leave claims.

Disposition

dismissed