Johnson v. Starbucks Corporation

Background

Summer-Annie N. Johnson, who was proceeding without a lawyer, sued Starbucks Corporation over events during her employment at a Starbucks location in Goshen, Orange County, New York. She alleged that, on June 7, 2024, an acting manager named Cam spoke to her in a condescending manner, causing her to leave a scheduled shift. The next day, another acting manager told her that someone else would cover her shift. District manager Tate Jacobs reportedly told Johnson that he had arranged the coverage because of the earlier incident. Johnson characterized this as retaliation, filed a complaint through the company's ethics-reporting system, and alleged that Jacobs later terminated her during the investigation. The investigation ruled in Jacobs's favor, and Johnson then filed with the Equal Employment Opportunity Commission. She sought $50,000 in damages.

The court had previously allowed Johnson to proceed without paying filing fees. For such cases, federal law requires dismissal of claims that are frivolous, malicious, fail to state a legally viable claim, or seek money from an immune defendant. The court also must dismiss claims when it lacks subject-matter jurisdiction, meaning legal authority to hear them.

Federal Claim

Because Johnson referred to an Equal Employment Opportunity Commission filing and alleged retaliation by her employer, the court interpreted the complaint as asserting a claim under Title VII of the Civil Rights Act of 1964. Title VII prohibits employment discrimination because of race, color, religion, sex, or national origin and protects employees from retaliation for opposing conduct that Title VII makes unlawful.

The court held that Johnson had not stated a Title VII claim because she did not allege that Starbucks mistreated her because of race, color, religion, sex, or national origin. The court granted her 60 days to amend the complaint to allege facts supporting any Title VII claim she wished to pursue.

Possible State-Law Claims

Johnson invoked diversity jurisdiction for her claims. Diversity jurisdiction generally requires the parties to be citizens of different states and requires a reasonable probability that more than $75,000 is at stake. The court said the allegations appeared to show diverse citizenship, but Johnson's demand for $50,000 did not satisfy the required amount. The court therefore concluded that it lacked diversity jurisdiction over any state-law claims she might be asserting. It noted that state-law claims could potentially be heard along with a viable federal claim under supplemental jurisdiction.

Leave to Amend and Disposition

The court granted Johnson leave to file an amended complaint within 60 days. The amended complaint must replace, rather than supplement, the original complaint, so Johnson must repeat any facts or claims she wants the court to consider. The court instructed her to identify relevant people and their titles, describe the relevant events and dates and locations, explain her injuries, and state the relief sought.

The order required the amended complaint to be filed with the Pro Se Intake Unit, labeled “Amended Complaint,” and marked with docket number 24-CV-6266 (LTS). No summons would issue at that time. If Johnson failed to comply within the allowed period and could not show good cause, the complaint would be dismissed for failure to state a claim. The court also certified that an appeal would not be taken in good faith and denied Johnson permission to proceed without paying fees for an appeal.