Coleman v. IEH Autoparts LLC

Background

Chanté Coleman, representing herself, brought an employment-discrimination action against IEH Autoparts LLC under the court’s federal-question jurisdiction. The court had previously allowed her to proceed without paying filing fees in advance.

Coleman used the court’s employment-discrimination complaint form and checked the box for the Americans with Disabilities Act (ADA). She identified her disability or perceived disability as “1995.” She also checked boxes alleging termination, failure to accommodate a disability, retaliation, and harassment or a hostile work environment.

Coleman alleged that she had worked with Auto Plus for two years and transferred from New Jersey to New York because of a domestic-violence partner. She said that, after arriving at the New York location, a coworker training her did not provide information she needed to perform her job. She alleged that she struggled with her tasks, was bullied for four months, was denied personal leave, and was fired after the coworker created a hostile work environment. She attached a February 21, 2024, Notice of Right to Sue from the Equal Employment Opportunity Commission. She did not identify the relief she was seeking.

Court’s analysis

Because Coleman was proceeding without a lawyer and without prepaying filing fees, the court screened her complaint under 28 U.S.C. § 1915(e)(2)(B). That law requires dismissal of an eligible complaint that is frivolous, malicious, fails to state a claim for relief, or seeks money from an immune defendant. The court also must dismiss claims over which it lacks subject-matter jurisdiction.

The court explained that the ADA prohibits discrimination against a qualified person because of a disability in the terms and conditions of employment. An ADA disability is a physical or mental impairment that substantially limits one or more major life activities. At the pleading stage, a plaintiff must provide facts making it plausible that the employer took an adverse employment action and that a protected characteristic was a motivating factor.

The court found that Coleman did not specify her disability. It also found that her allegations did not suggest that IEH took an adverse employment action because of a disability, a perceived disability, or another characteristic protected by federal employment-discrimination laws. The court therefore concluded that she failed to state a claim under the federal employment-discrimination statutes.

The court also addressed the possibility of state-law claims based on domestic-violence-victim status. It stated that New York law protects employees from discrimination based on that status, but that the court lacked diversity jurisdiction over such claims because Coleman alleged that both she and IEH were residents of New York. The court further declined, at that stage, to exercise supplemental jurisdiction over any state-law claims because no viable federal claim had been stated.

Disposition and practical effect

The court granted Coleman leave to file an amended complaint within 60 days. The amended complaint must state additional facts showing that an adverse employment action occurred because of a protected characteristic, such as race, color, age, sex, national origin, or disability. It must identify relevant people and their titles, describe what each defendant did or failed to do and when and where it happened, describe her injuries, and state the relief she seeks. The amended complaint will replace the original complaint rather than supplement it, so facts or claims Coleman wants to preserve must be repeated.

The court directed Coleman to submit the amended complaint to the court’s Pro Se Intake Unit, label it “Amended Complaint,” and include docket number 24-CV-3507 (LTS). No summons would issue at that time. The order states that if she does not comply within the permitted period and cannot show good cause, the complaint will be dismissed for failure to state a claim. Judge Laura Taylor Swain also certified that an appeal would not be taken in good faith and denied Coleman permission to proceed without prepaying fees for an appeal.