Michael Williams v. Amdocs Inc. et al.

Summary

This magistrate judge's findings, conclusions, and recommendation addresses a pro se employment-discrimination action asserting claims under Title VII, 42 U.S.C. § 1981, and Texas intentional infliction of emotional distress law. The recommendation concludes that the Title VII and state tort claims are barred by applicable statutes of limitations and should be dismissed with prejudice. It finds that the § 1981 claim does not appear time-barred because the complaint was filed exactly four years after the alleged termination.

Holdings

1. A Title VII civil action must generally be filed within ninety days after receipt of the EEOC right-to-sue letter; Williams's Title VII claims were time-barred based on the facts alleged in the complaint.
2. A prior Title VII action dismissed for failure to prosecute does not toll the ninety-day period for filing a subsequent Title VII action.
3. Williams did not plead facts supporting equitable tolling of the Title VII limitations period.
4. The Texas intentional-infliction-of-emotional-distress claim was barred by Texas's two-year statute of limitations, and the prior state-court action did not toll the limitations period.
5. Williams's § 1981 claim did not appear to be time-barred because he filed suit exactly four years after the alleged June 17, 2021 termination.

Questions Presented

1. Whether the Title VII claims were clearly barred by the ninety-day period for filing suit after receipt of an EEOC right-to-sue letter.
2. Whether the prior state-court action tolled the limitations period for the Title VII claims.
3. Whether equitable tolling could preserve the Title VII claims.
4. Whether the Texas intentional-infliction-of-emotional-distress claim was barred by the two-year statute of limitations and whether the prior state-court action tolled that period.
5. Whether the § 1981 claim was barred by the four-year federal statute of limitations.

Disposition

other