Naquaylia Rhodes v. Play Pen, Inc. and Michael W. Bickers d/b/a Club Coyote

Summary

The United States District Court for the Southern District of Indiana denied Michael Bickers's motion for judgment on the pleadings concerning Naquaylia Rhodes's ADA employment-discrimination complaint. The court held that Rhodes plausibly alleged disability, qualification, and adverse employment action based on her HIV status. The court granted Rhodes's motion to dismiss Bickers's counterclaim, concluding that it was conclusory and based on statements absolutely privileged in judicial proceedings.

Holdings

1. Rhodes stated a plausible ADA claim by alleging that she was disabled within the meaning of the ADA because of her HIV-positive status, was able to perform the essential functions of her job with or without accommodation, and suffered suspension and termination because of her disability.
2. The counterclaim failed to state a claim because it consisted of conclusory allegations that Rhodes's complaint was false and was based on statements made in the litigation that were absolutely privileged.
3. The court had supplemental jurisdiction over the counterclaim because it shared a common nucleus of operative fact with Rhodes's ADA claim, even though the counterclaim was ultimately dismissed for failure to state a claim.

Questions Presented

1. Whether Rhodes plausibly alleged an ADA employment-discrimination claim against Bickers.
2. Whether Bickers's motion filed after his answer should be treated as a Rule 12(c) motion for judgment on the pleadings.
3. Whether supplemental jurisdiction extended to Bickers's counterclaim.
4. Whether Bickers's counterclaim stated a claim for relief despite its conclusory allegations and reliance on statements made in Rhodes's judicial pleadings.

Disposition

other