Jones v. Scnider Electrics

Background

Kevin Lawrence Jones sued Schneider Electric USA, Inc., Volt Management Corp., and Brandon Puffer. The opinion states that Jones was proceeding without a lawyer and had been allowed to proceed without paying filing fees. Jones alleged violations of federal and California employment and antidiscrimination laws, California wage laws, and a claim for intentional infliction of emotional distress.

Jones alleged that he was a temporary employee supervised by Puffer, whom the complaint identified as a warehouse manager at Schneider Electric. Jones alleged that Puffer sent a racist group text targeting Black people, made racist comments and jokes, used a racial slur, made comments associating Jones with slavery and gang activity, engaged in racially discriminatory conduct on social media, and made sexual comments to or about Jones.

Jones also alleged that on June 15, 2021, he accidentally sent a text saying he would be late to the wrong coworker rather than to Puffer. Puffer then terminated him, stating that Jones was a “no call/no show.” Jones further alleged that his final paycheck was late and did not include all compensation owed to him, causing significant emotional distress.

Claims and screening

The court screened Jones’s second amended complaint under 28 U.S.C. § 1915, which requires dismissal of a complaint filed by a person proceeding without paying filing fees if it is frivolous, malicious, fails to state a claim for relief, or seeks money from a defendant protected from such relief.

Jones’s federal claim alleged race discrimination under 42 U.S.C. § 1981. The court stated that this claim required allegations that Jones belonged to a racial group, a contractual right was impaired, the defendant intentionally discriminated against him because of race, and race was the necessary cause of the contractual impairment.

The court found that Jones adequately alleged facts supporting the first three elements. It concluded, however, that the complaint did not adequately allege the required causation. Jones alleged that he was late, accidentally failed to notify his supervisor, and was terminated because his supervisor treated him as a “no call/no show.” The court concluded that these allegations identified a reason for the termination separate from the alleged racial discrimination, so race was not adequately alleged to be the necessary cause of the termination.

Jurisdiction over state claims

The court concluded that the § 1981 claim was the only claim supporting federal-question jurisdiction. It also determined that the complaint did not establish diversity jurisdiction because Jones did not specify his state citizenship and alleged that Volt was headquartered in California. The court therefore declined to exercise supplemental jurisdiction—the federal court’s authority to hear related state-law claims—over Jones’s five state-law claims after dismissing the federal claim.

Rulings

The court granted Jones leave to file the second amended complaint, construing his filing as a request to amend because the defendants had not yet been served. The court then dismissed the second amended complaint with leave to amend for failure to state a claim. Jones was permitted to file a third amended complaint by July 17, 2025. The court stated that it would not order service by the United States Marshals Service unless Jones stated a viable federal claim.

Because the operative complaint had been dismissed, the court denied Jones’s motion to compel arbitration and motion for equitable tolling as moot and without prejudice.

Judge and date issue

The supplied case metadata identifies Jacquelyn Corley as the judge, but the opinion’s signature identifies Beth Labson Freeman. This summary uses the judge identified in the opinion’s signature.