Coleman v. IEH Autoparts LLC

Background

Coleman, proceeding without a lawyer and without paying court fees, sued IEH Autoparts LLC. Her original complaint alleged that her employer discriminated against her because of an unspecified disability under the Americans with Disabilities Act of 1990 (ADA). The court directed her to amend the complaint to address deficiencies, and she filed an amended complaint on November 14, 2024.

The amended complaint again asserted ADA claims and added claims under Title VII of the Civil Rights Act of 1964 based on race and color. Coleman did not identify the disability or perceived disability at issue, and she did not specify the race or color with which she identifies. Her attachment described workplace interactions, training problems, and treatment by coworkers and supervisors, but the court found that it did not provide facts suggesting that the employer took an adverse employment action because of disability, race, or color.

ADA claims

The court dismissed the ADA claims for failure to state a claim on which relief may be granted. It held that Coleman did not identify her disability and did not allege facts suggesting that her employer took an adverse employment action because of a disability or perceived disability. The dismissal was entered under 28 U.S.C. § 1915(e)(2)(B)(ii), which requires dismissal of a qualifying fee-waived action that fails to state a claim.

Title VII claims

The court also dismissed Coleman’s Title VII claims for failure to state a claim. The court explained that a plaintiff must plausibly allege an adverse employment action and facts showing that race or color was a motivating factor. Coleman’s allegations that coworkers treated her unfairly, looked at her in a certain way, or interacted with people of their own race did not suggest that her employer took an adverse employment action because of her race or color.

State-law claims and further amendment

After dismissing the federal claims, the court declined to exercise supplemental jurisdiction over any state-law claims Coleman might be asserting. Supplemental jurisdiction is a federal court’s authority to hear related state-law claims; the court declined to use that authority after the federal claims were dismissed.

The court also denied further leave to amend. It explained that Coleman had already been given an opportunity to correct the deficiencies and had not done so in the amended complaint.

Disposition

The court dismissed the action for failure to state a claim, declined to exercise supplemental jurisdiction over any state-law claims, and directed the Clerk of Court to enter judgment. It certified that any appeal would not be taken in good faith and denied Coleman’s fee-waiver status for purposes of an appeal.