Gipson v. RJ
- Jeffrey Bryan
- 0:24-cv-03615
- U.S. District Court · District of Minnesota
- 3
In Gipson v. RJ, Judge Bryan dismissed Isis Gipson’s complaint without prejudice and denied her fee-waiver application as moot because it did not state a plausible claim.
Isis Gipson’s lawsuit was dismissed without prejudice. The defendants were not subjected to a merits ruling on the state-law claims, and Gipson’s application to proceed without paying the filing fee was denied as moot.
What happened
In Gipson v. RJ, Isis Gipson sued several defendants under Title VII, the Minnesota Human Rights Act, and Minnesota common law. She also applied to proceed without paying the filing fee.
The court found that Gipson did not identify her employer as a defendant or identify her employer at all, so she did not state a plausible Title VII claim. The court also noted that the complaint did not describe the alleged discriminatory, harassing, or defamatory conduct in enough detail. Because the federal claim was dismissed, the court declined to decide the state-law claims.
Judge Jeffrey M. Bryan dismissed the complaint without prejudice and denied Gipson’s application to proceed without paying the filing fee as moot.
The detailed version
- Gipson v. RJ · No. 0:24-cv-03615
- Jeffrey M. Bryan
- Nov. 15, 2024
Background
Isis Gipson filed a complaint against RJ, identified as “First shift,” and several other defendants. She asserted claims under Title VII of the Civil Rights Act of 1964, the Minnesota Human Rights Act, and Minnesota common law. She also submitted an application to proceed without paying the filing fee.
Court’s analysis
The court reviewed the complaint under 28 U.S.C. § 1915(e)(2)(B)(ii), which requires dismissal when a complaint filed with a request to proceed without paying the filing fee fails to state a claim for relief. The court said that factual allegations are accepted as true at this stage and that complaints by people representing themselves are read liberally, but they still must include enough facts to make the claim plausible.
Title VII prohibits covered employers from discriminating against individuals because of race, color, religion, sex, or national origin. The court held that Gipson’s complaint did not identify her employer as a defendant and did not identify the employer at all. For that reason, she did not state a plausible Title VII claim.
The court also expressed concern that the complaint did not allege facts showing that Gipson had completed the required administrative process before bringing a Title VII lawsuit. In addition, the court found the allegations conclusory and not specific. Other than one reference to insulting comments by coworkers, the complaint did not describe the defendants’ alleged discriminatory, harassing, or defamatory actions in detail sufficient to state a Title VII claim.
Gipson’s remaining claims arose under the Minnesota Human Rights Act and Minnesota common law, including defamation. After dismissing the federal claim, the court declined to exercise supplemental jurisdiction—the authority to decide related state-law claims—in light of the federal claims being dismissed before trial.
Disposition
Judge Jeffrey M. Bryan ordered that Gipson’s complaint be DISMISSED WITHOUT PREJUDICE. The court also ordered that Gipson’s application to proceed without paying the filing fee be DENIED as moot. The order directed that judgment be entered accordingly.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.