Ahmed v. Board of Governors of the Federal Reserve Bank

Background

Aden A. Ahmed sued the Federal Reserve Bank of Minneapolis and the Board of Governors of the Federal Reserve Bank. The first case, Civil No. 24-16, was filed in state court and removed to federal court by the Federal Reserve Bank of Minneapolis. Ahmed represented himself. He alleged that, while working for the Federal Reserve Bank between 2009 and 2016, he was treated unfairly, harassed, stalked, and targeted after reporting violations of laws and regulations. He also alleged that information was spread to harm his career, that property was stolen or damaged, and that his car was impounded and bugged.

Ahmed further alleged that he was injured at work and became permanently disabled, including through post-traumatic stress disorder, attention deficit disorder, anxiety, and depression. He said he was prevented from speaking with elected officials and the media and was denied legal representation. The opinion identifies claims under Title VII, the Americans with Disabilities Act, the Whistleblower Protection Act, and Minnesota workers’ compensation laws, as well as constitutional, defamation, and conversion claims.

Ahmed also filed Civil No. 24-1790 against the Federal Reserve Bank of Minneapolis and its Board of Governors. The court determined that the second lawsuit appeared entirely duplicative of the first. Because Ahmed sought 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) and concluded that it failed to state a claim for the same reasons as the first complaint.

Court’s analysis

The court applied the standard for a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6). At that stage, the court generally assumes the complaint’s factual allegations are true and draws reasonable inferences in the plaintiff’s favor, but it does not accept wholly conclusory allegations or legal conclusions. A self-represented complaint receives a more forgiving reading, but it still must allege facts rather than unsupported conclusions.

The court held that Ahmed’s Title VII and Americans with Disabilities Act claims were untimely. He stopped working at the Federal Reserve Bank in 2016, filed an Equal Employment Opportunity Commission charge in 2023, received a notice of the right to sue on April 28, 2023, and filed this action on December 6, 2023—more than seven months later. The court therefore dismissed those claims as untimely.

The court dismissed Ahmed’s constitutional claims without prejudice because he did not identify specific conduct by the defendants that plausibly supported a constitutional violation. It dismissed the Whistleblower Protection Act claim with prejudice because the cited statute does not create a private right of action.

The court also held that the Minnesota workers’ compensation claim was barred by the state law’s six-year filing period. Because seven years had passed between the end of Ahmed’s employment and the filing of the action, the court dismissed that claim with prejudice. His defamation and conversion claims were dismissed without prejudice because he did not allege specific conduct that plausibly supported either claim.

The court stated that the Federal Reserve Bank also argued that Ahmed had signed a separation agreement, but it did not decide that issue because the claims were untimely.

Disposition

Judge Donovan W. Frank granted the Federal Reserve Bank’s motion to dismiss in Civil No. 24-16. The court dismissed with prejudice Ahmed’s claims under Title VII, the Americans with Disabilities Act, the Whistleblower Protection Act, and Minnesota workers’ compensation laws. It dismissed without prejudice his constitutional claims and state-law defamation and conversion claims.

For Civil No. 24-1790, the court dismissed with prejudice the Title VII, Americans with Disabilities Act, Whistleblower Protection Act, and Minnesota workers’ compensation claims, and dismissed without prejudice the constitutional, defamation, and conversion claims. The order directed that judgment be entered.