Robinson v. AETNA

Background

Lakiea Robinson filed the action without a lawyer and had previously been allowed to proceed without prepaying filing fees. She alleged discrimination, retaliation, and a hostile work environment. Her complaint invoked Title VII of the Civil Rights Act of 1964, the Age Discrimination in Employment Act, the Americans with Disabilities Act, the Rehabilitation Act, the Family and Medical Leave Act, 42 U.S.C. § 1981, and the New York State Human Rights Law. She also mentioned the Employee Retirement Income Security Act and the Genetic Information Nondiscrimination Act in the requested relief.

Robinson alleged that in March 2017 she requested Family and Medical Leave Act leave to go to Catholic Charities, but the request was denied at management’s direction. She alleged that Aetna did not accept her request or treat her fairly and described the workplace as toxic. The complaint stated that Robinson’s employment was with Coca-Cola and alleged that Aetna was apparently Coca-Cola’s Family and Medical Leave Act administrator. Robinson did not allege in this complaint that Coca-Cola fired her. She sought disability accommodation and money damages.

Court’s analysis

The court applied the screening standard for complaints filed by people allowed to proceed without prepaying fees. Under that standard, the court must dismiss claims that are frivolous, malicious, legally insufficient, seek money from an immune defendant, or fall outside the court’s subject-matter jurisdiction. The court also explained that a self-represented complaint receives a liberal reading but still must provide a short and plain statement showing entitlement to relief.

The court held that Robinson’s complaint failed to satisfy that requirement. Regarding the Family and Medical Leave Act, Robinson did not allege facts showing that she was eligible for leave, why the request was denied, or how the denial amounted to interference with or retaliation for exercising rights under that law. Regarding discrimination, she did not provide facts connecting any action by Aetna to her race, color, sex, age, or disability. The court also found that she did not explain how Aetna was involved in the hostile work environment she attributed to her work at Coca-Cola.

The court noted that the Rehabilitation Act applies only to entities receiving federal financial assistance, and Robinson did not allege that Aetna received such funding. It also stated that any ERISA or Genetic Information Nondiscrimination Act claims would require Robinson to explain how those laws related to her allegations. For the New York State Human Rights Law claim, Robinson did not allege the parties’ citizenship or facts showing that the amount in dispute exceeded $75,000. The court deferred deciding whether to exercise supplemental jurisdiction over any state-law claims because Robinson was being given an opportunity to amend.

Rulings

The court granted Robinson leave to file an amended complaint within 60 days. The amended complaint must replace the original complaint rather than supplement it and must provide facts identifying what each defendant did, when and where the events occurred, the injuries Robinson suffered, and the relief sought. The court also directed Robinson to address why her claims were not untimely and to provide facts showing that Aetna, separately from Coca-Cola, could be liable under the statutes she cited.

The court denied without prejudice Robinson’s motion for pro bono counsel because it was too early to assess the merits and the request could be renewed later. It also denied without prejudice her motion for an order of service as premature because the complaint failed to state a claim. No summons would issue at that time. The court stated that if Robinson failed to amend within the allowed period and could not show good cause, the complaint would be dismissed for failure to state a claim. The court further certified that an appeal would not be taken in good faith and denied fee-free status for an appeal.