Scott v. Home Depot USA, Inc.

Background

Morris Scott, who is proceeding without a lawyer, sued Home Depot USA, Inc., Dan Grace, Briget [Coordinator], Anthony Ferriole [Mngr], Carlos [Spvsr], Rolando [Customer Care], Jaymz [Mngr], and Brandon [Mngr]. 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 pneumonia, rapid heartbeat, and kidney failure, from January 2020 through December 20, 2024. 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 paying filing fees in advance, the court was required to screen his complaint. The court explained that it must dismiss such a complaint, or part of it, if it is frivolous, malicious, fails to state a claim for relief, seeks money from an immune defendant, or falls outside the court’s subject-matter jurisdiction. The court also explained that complaints filed without a lawyer are read liberally, but they still must provide enough factual detail to make the claims plausible.

The court found that the complaint did not provide enough information for the court or the defendants to determine whether Scott was entitled to relief. It did not describe what exactly happened or explain why each defendant violated his rights. The allegations about health complications, the Equal Employment Opportunity Commission charge, police assistance, and termination nearly eight months after the charge did not suggest that Home Depot or the individual defendants engaged in discriminatory conduct. Without concrete facts about each defendant’s conduct, the defendants could not respond adequately to the complaint.

Disposition

The court granted Scott leave to file an amended complaint within 60 days of the order. The amended complaint must provide a short and plain statement of the facts supporting each claim against each defendant, including relevant names and titles, what each defendant did or failed to do, approximate dates and locations, Scott’s injuries, and the relief he seeks. It must be labeled “Amended Complaint” and include docket number 25-CV-2191 (LLS).

The amended complaint will completely replace the original complaint rather than supplement it, so Scott must repeat any facts or claims from the original that he wants the court to consider. No summons will issue at this time. The court stated that if Scott does not comply within the allowed period and cannot show good cause, the complaint will be dismissed for failure to state a claim.