Jawuan Crystal Boykin v. Catalent Pharma Solutions

Summary

The United States District Court for the Southern District of Indiana ruled on motions in Jawuan Crystal Boykin's Title VII and negligence action against Catalent Pharma Solutions. The court denied Boykin's motions for default judgment and to compel a responsive pleading, granted in part and denied in part Catalent's motion to dismiss, dismissed the harassment and negligence claims, and allowed the Title VII retaliation claim to proceed. Catalent was ordered to file a responsive pleading to the retaliation claim within fourteen days, by May 5, 2026.

Holdings

1. A defendant is not required to file a responsive pleading while a timely Rule 12(b)(6) motion is pending; therefore, Boykin was not entitled to default judgment or an order compelling a responsive pleading.
2. The Title VII harassment claim failed because Boykin did not allege that the harassment was based on a characteristic protected by Title VII.
3. Boykin adequately pleaded a Title VII retaliation claim, which therefore survived the motion to dismiss.
4. The negligence claim failed because Boykin did not establish that Indiana common law imposed the alleged duty on Catalent.

Questions Presented

1. Whether Boykin was entitled to default judgment or an order compelling a responsive pleading while Catalent's timely Rule 12(b)(6) motion was pending.
2. Whether Boykin adequately pleaded a Title VII harassment or hostile-work-environment claim.
3. Whether Boykin adequately pleaded a Title VII retaliation claim.
4. Whether Boykin adequately pleaded negligence under Indiana law.

Disposition

other