Ahmed v. Federal Reserve System Board of Governors
- Donovan Frank
- 0:24-cv-01790
- U.S. District Court · District of Minnesota
- 8
In Ahmed v. Board, Judge Frank dismissed employment and other claims, some with prejudice and some without prejudice, for untimeliness or insufficient allegations.
Aden A. Ahmed’s claims against the Board of Governors of the Federal Reserve Bank or Federal Reserve System Board of Governors and the Federal Reserve Bank of Minneapolis were dismissed. The order covers Civil Nos. 24-16 and 24-1790.
What happened
In Ahmed v. Board of Governors of the Federal Reserve Bank, Aden A. Ahmed sued the Board of Governors and the Federal Reserve Bank of Minneapolis over alleged workplace mistreatment, retaliation, disability, and related harms. He asserted claims under Title VII, the Americans with Disabilities Act, the Whistleblower Protection Act, Minnesota workers’ compensation laws, and state and constitutional law. He also filed a second, apparently duplicative case.
The court concluded that Ahmed’s Title VII and disability claims were filed too late because the alleged employment conduct ended by 2016, his notice allowing a lawsuit arrived on April 28, 2023, and he filed suit more than 90 days later. The court also found that his whistleblower and workers’ compensation claims could not proceed, while his constitutional, defamation, and conversion claims did not allege enough specific conduct.
Judge Donovan W. Frank granted the Federal Reserve Bank’s motion to dismiss in Civil No. 24-16. In that case, the court dismissed the Title VII, disability, whistleblower, and workers’ compensation claims with prejudice, and dismissed the constitutional, defamation, and conversion claims without prejudice. The court ordered the same claim-level outcomes in Civil No. 24-1790 after screening that second case.
The detailed version
- Ahmed v. Federal Reserve System Board of Governors · No. 0:24-cv-01790
- Donovan Frank
- July 3, 2024
Background
Aden A. Ahmed brought Civil No. 24-16 in state court against his former employer, the Federal Reserve Bank, and the Board of Governors of the Federal Reserve Bank. The Federal Reserve Bank removed the case to federal court and moved to dismiss. Ahmed represented himself and responded with a letter asking the court to deny the motion.
Ahmed alleged that, between 2009 and 2016, he was targeted and treated unfairly at work, experienced harassment and stalking, reported violations of laws and regulations, and was later targeted. He also alleged that the Federal Reserve Bank spread misinformation about him, that property was stolen or damaged, and that his car was impounded and bugged. He alleged that he was injured while working for the Federal Reserve Bank and became permanently disabled, suffering from post-traumatic stress disorder, attention deficit disorder, anxiety, and depression.
Ahmed appeared to assert claims under Title VII, the Americans with Disabilities Act, the Whistleblower Protection Act, and Minnesota workers’ compensation laws. He also asserted constitutional claims and claims for defamation and conversion.
Ahmed separately filed Civil No. 24-1790 against the Federal Reserve System Board of Governors and the Federal Reserve Bank of Minneapolis. The court determined that the second case appeared entirely duplicative of the first. Because Ahmed requested permission to proceed without paying filing fees in the second case, the court screened that complaint under 28 U.S.C. § 1915(e)(2)(B).
Legal standards
For a motion to dismiss under Rule 12(b)(6), the court assumes the complaint’s factual allegations are true and draws reasonable inferences in the complainant’s favor. But the complaint must include enough factual detail to state a claim that is plausible, rather than relying on unsupported conclusions.
The court also explained that complaints filed by people without lawyers receive less demanding pleading treatment, but they still must allege facts rather than only bare legal conclusions.
Court’s analysis
The court dismissed Ahmed’s Title VII and Americans with Disabilities Act claims as untimely. Ahmed alleged that he stopped working at the Federal Reserve Bank in 2016, so the alleged employment practices occurred no later than then. He filed an Equal Employment Opportunity Commission charge in 2023, years after the applicable deadline. He also received a notice of the right to sue on April 28, 2023, but filed this action on December 6, 2023, more than seven months later and outside the 90-day filing period.
The court dismissed the constitutional claims without prejudice because Ahmed did not allege specific conduct by the defendants that plausibly supported a constitutional violation.
The court dismissed the Whistleblower Protection Act claim with prejudice because, according to the court, the statutory provision at issue does not create a private right of action.
The court dismissed the Minnesota workers’ compensation claim with prejudice. Minnesota law requires such an action to begin no more than six years after the injury, and the court found a seven-year gap between the end of Ahmed’s employment and the filing of this action.
The court dismissed the defamation and conversion claims without prejudice because Ahmed did not allege specific conduct that plausibly supported either claim. The court did not reach the Federal Reserve Bank’s separate argument concerning a separation agreement because it found the claims untimely.
For Civil No. 24-1790, the court concluded that the complaint failed to state a claim for the same reasons as the first complaint and dismissed the second case accordingly.
Disposition
For Civil No. 24-16, Judge Donovan W. Frank granted the Federal Reserve Bank’s motion to dismiss. The court dismissed Ahmed’s claims under Title VII, the Americans with Disabilities Act, the Whistleblower Protection Act, and Minnesota workers’ compensation laws with prejudice. It dismissed his constitutional claims and state-law defamation and conversion claims without prejudice.
For Civil No. 24-1790, the court dismissed the Title VII, Americans with Disabilities Act, Whistleblower Protection Act, and Minnesota workers’ compensation claims with prejudice. It dismissed the constitutional, defamation, and conversion claims without prejudice. The order directed that judgment be entered.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.