Scott v. Home Depot USA, Inc.

Background

Morris Scott, proceeding without a lawyer, sued Home Depot USA, Inc. and seven individual defendants. He invoked Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 1981, the Age Discrimination in Employment Act, the Americans with Disabilities Act, the Rehabilitation Act, and the New York State Human Rights Law. He alleged discrimination based on race, color, religion, sex, age, and disability.

Scott alleged that Home Depot management caused him personal injuries and hospitalizations, including hospitalization for pneumonia, rapid heartbeat, and kidney failure. He also alleged that Home Depot fired him on December 20, 2024. According to the complaint, he filed a discrimination charge with the Equal Employment Opportunity Commission on April 26, 2024, and asked for police assistance about 10 times between May and December 2024.

Court’s Analysis

Because Scott had been allowed to proceed without prepaying filing fees, the court screened his complaint under 28 U.S.C. § 1915(e)(2)(B). The court also applied the requirement that a complaint provide a short and plain statement showing entitlement to relief and contain enough factual matter to make the claim plausible.

The court concluded that the complaint did not provide enough information for the court or the defendants to determine what occurred or why each defendant allegedly violated Scott’s rights. The allegations about injuries, hospitalizations, the Equal Employment Opportunity Commission charge, police assistance, and termination did not, in the court’s view, suggest that Home Depot or the individual defendants engaged in discriminatory conduct. The court stated that Scott needed to provide concrete facts describing each defendant’s conduct.

Disposition

The court granted Scott leave to file an amended complaint within 60 days. The amended complaint must identify relevant people and titles, describe the relevant events and each defendant’s actions or failures to act, provide approximate dates and locations, describe Scott’s injuries, and state the relief sought. The amended complaint will replace the original complaint rather than supplement it, so Scott must repeat any facts or claims he wants the court to consider.

The court directed Scott to submit the amended complaint to the Pro Se Intake Unit, label it “Amended Complaint,” and include docket number 25-CV-2191 (LLS). No summons would issue at that time. The order states that if Scott fails to comply within the allowed period and cannot show good cause for the failure, the complaint will be dismissed for failure to state a claim.