Moore v. Stripe, Inc.

Background

Charisse S. Moore, proceeding without a lawyer, sued Stripe, Inc. She invoked federal-question jurisdiction and identified employment-discrimination claims under Title VII, 42 U.S.C. § 1981, the Age Discrimination in Employment Act, the Rehabilitation Act, the Americans with Disabilities Act, and the Family and Medical Leave Act. She also asserted state-law discrimination, stalking, and equal-pay claims.

Moore alleged that she interviewed for and worked at Stripe beginning in 2022. Her allegations included difficulties during onboarding, problems contacting a Stripe employee for information-technology assistance, a denied salary or cost-of-living adjustment after she moved to New York, being assigned a different hotel from other employees during a company trip to Ireland, a negative performance evaluation, and alleged secret recording or distribution of a therapy session. She said that these events, along with a broader alleged stalking scheme, caused her to leave Stripe and amounted to a constructive discharge, meaning that working conditions allegedly forced her to resign. Stripe had granted her requests for a leave of absence and a transfer to the New York City area.

Legal standard

The court explained that a self-represented complaint must be read liberally but still must provide a plausible claim for relief. Rule 8 requires a short, plain, coherent statement of the claim. Rule 12(b)(6) permits dismissal when a complaint fails to state a claim on which relief can be granted. The court also explained that a complaint may be dismissed as frivolous under 28 U.S.C. § 1915(e)(2)(B)(i) when its factual allegations are clearly baseless or its legal theory has no arguable basis.

Court’s analysis

The court held that Moore had not plausibly alleged an actionable adverse employment action, discrimination based on a protected characteristic, harassment, retaliation, or denial of a disability accommodation. It identified the possible bases for her alleged constructive discharge as the negative performance evaluation, difficulty reaching the Stripe employee, the conclusory allegation about secretly recorded therapy sessions, and the different hotel assignment. The court concluded that these allegations did not plausibly establish a legal violation. It also found that Moore had not alleged that Stripe denied a request for accommodation and that she offered no plausible support for the broader alleged stalking conspiracy.

The court concluded that the complaint failed both Rule 8’s requirements for clarity and Rule 12(b)(6)’s plausibility requirement. It also deemed the complaint frivolous under the statute governing certain complaints filed without prepayment of fees. Stripe separately argued that Moore had released her claims through a severance package and had failed to complete required administrative procedures, but the court said it did not need to address those arguments because of the complaint’s other defects.

Disposition

Judge Oetken granted Stripe’s motion to dismiss. The court dismissed Moore’s federal claims with prejudice and deemed them frivolous under 28 U.S.C. § 1915(e)(2)(B)(i). It dismissed her state-law claims without prejudice to refiling in state court. The court declined to allow amendment because it found the complaint’s defects could not be cured. It directed the clerk to enter judgment, terminate pending motions, and close the case.

The court warned that future frivolous or duplicative cases could lead to an order barring Moore from filing new cases without prepaying filing fees unless she first obtained the court’s permission. It also certified that any appeal would not be taken in good faith and denied permission to proceed without prepaying fees for an appeal.