Daniels v. Wyndham Destinations

Background

Earland Fitz Daniels brought the action against Wyndham Destinations under Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act of 1990, and the New York State Human Rights Law. He alleged employment discrimination based on sex and disability. Daniels was proceeding without a lawyer, and the court had previously allowed him to proceed without prepaying filing fees.

The complaint alleged that Daniels was placed around people who harassed and bullied him while Wyndham knew about the situation. He also alleged that someone at a work site called him a “pretty boy.” Daniels stated that he had a herniated disc and remained on medical leave.

Court’s Reasoning

The court explained that a complaint must give a short and plain statement showing that the plaintiff is entitled to relief. At the initial review required for a case filed without prepaying fees, the court must dismiss a complaint that is frivolous, malicious, fails to state a claim, seeks money from an immune defendant, or falls outside the court’s subject-matter jurisdiction.

The court found that Daniels did not provide enough concrete facts for the court or Wyndham to determine whether he plausibly had a claim. The allegation that someone called him a “pretty boy” did not, by itself, show that Wyndham treated him differently because of sex or created a hostile work environment. The court also found that stating only that Daniels had a herniated disc and was on medical leave did not describe discriminatory conduct based on disability.

Order

The court granted Daniels leave to file an amended complaint within 60 days of the order. The amended complaint must explain who violated his rights, what each defendant did or failed to do, when and where the events occurred, what injuries Daniels suffered, and what relief he seeks. It must replace the original complaint, so any facts or claims Daniels wants to preserve must be repeated in the amended version.

The court directed Daniels to submit the amended complaint to the court’s Pro Se Intake Unit, label it “Amended Complaint,” and include docket number 25-CV-2208 (LLS). No summons would issue at that time. The court stated that if Daniels failed to comply within the allowed time and could not show good cause, the complaint would be dismissed for failure to state a claim.

Classification

This is a procedural order because the court addressed whether the complaint was adequately pleaded during initial screening and allowed amendment without deciding the ultimate merits of the discrimination claims.