Williams v. The Plaza Rehabilitation and Nursing Center

Background

Robin A. Williams, who was representing herself and had been allowed to proceed without paying the filing fee, brought claims described as age, race, and gender discrimination against The Plaza Rehabilitation and Nursing Center, John Taylor, Crystal Roebuck, and Ricardo Graham. The complaint alleged that Williams quit after Taylor allegedly tried to punch her, that she was subjected to repeated shaming and harassment, and that she was sent home after being told that the defendants did not want to see her anymore. It also described comments about her body, mental health, alleged relationships, and sexual activity.

The complaint did not allege that Williams was employed by Plaza Rehabilitation and Nursing Center, and it did not state Williams’s race or age. An Equal Employment Opportunity Commission letter attached to the complaint stated that the agency was closing Williams’s charge because the facts alleged did not state a claim under the laws enforced by the agency. In a later declaration, Williams added allegations about insulting and threatening remarks, including remarks allegedly made by her supervisor.

Procedural history

The court referred the case to Magistrate Judge Barbara Moses. Judge Moses advised Williams that the allegations were insufficient to state plausible discrimination claims and gave her permission to amend the complaint. The deadline was later extended, but Williams did not file an amended complaint or otherwise respond. Judge Moses then recommended dismissal for failure to state a claim under the federal statute governing cases brought without payment of filing fees and Federal Rule of Civil Procedure 12(b)(6), which concerns whether a complaint adequately states a legal claim. Williams filed no objections.

Because there were no objections, Judge Gardephe reviewed the recommendation for clear error—that is, whether the record showed an obvious mistake.

Court’s analysis

The court explained that an age-discrimination claim under the Age Discrimination in Employment Act requires allegations showing, among other things, that the plaintiff is at least 40 years old and that an adverse employment action occurred under circumstances suggesting age discrimination. For race- and gender-discrimination claims under Title VII, the plaintiff must allege membership in a protected group, qualification for the position, an adverse employment action, and facts suggesting that the action resulted from race or gender discrimination.

The court found no error in Judge Moses’s recommendation. Neither the complaint nor Williams’s supplemental declaration stated her age or race, so the court could not determine from the pleadings that she belonged to the groups protected by the age- and race-discrimination statutes. Although the complaint contained allegations that could suggest a hostile work environment, the court found no allegations indicating that the conduct occurred because of Williams’s race, age, or gender. The court also noted that Williams had twice been directed to amend the complaint to address these deficiencies but had not done so.

Disposition

Judge Gardephe adopted the report and recommendation and dismissed the complaint for failure to state a claim. The order stated that any motion for permission to file an amended complaint had to be filed by July 31, 2024, with the proposed amended complaint attached. If no such motion was filed by that date, the clerk would be directed to close the case.