Hughes v. San Francisco Unified School District

Background

Auliya Hughes filed a complaint without a lawyer against the San Francisco Unified School District, Zachary Williams, and Kathy Ballou. She asserted claims under Title VII of the Civil Rights Act of 1964, alleging discrimination based on race, national origin, and religion. Hughes alleged that her temporary senior typist position with the District ended on December 23, 2024, and that she later applied for multiple District positions but was not rehired. She sought damages and other relief, including help with university loans, housing, car repossession, and requested declarations and injunctions.

The court had previously allowed Hughes to proceed without paying filing fees. That status required the court to screen her complaint and dismiss it if it was frivolous or malicious, failed to state a claim for relief, or sought money from a defendant legally protected from such relief.

Court’s analysis

The court found that Hughes’s complaint was not frivolous or malicious. The allegations had a sufficient factual and legal basis to avoid dismissal on those grounds.

The court nevertheless found that the complaint failed to state a plausible Title VII claim. First, the complaint did not allege that Hughes had timely exhausted the required administrative remedies, such as filing a charge with the Equal Employment Opportunity Commission or an appropriate state or local agency, before bringing the lawsuit.

Second, the court found that the allegations did not plausibly show discrimination because of race, national origin, or religion. The complaint did not provide allegations connecting the District’s hiring decisions to Hughes’s membership in a protected class. The court also found no alleged facts linking remarks or events involving San Francisco General Hospital or the San Francisco Department of Public Health to the District’s hiring decisions.

Finally, the court ruled that the individual defendants could not be held liable for damages under Title VII because they were not alleged to be Hughes’s employer. The court found that the District itself was not immune from the Title VII claims, but that there was no proper legal basis to include Williams or Ballou as defendants for the requested damages.

Disposition

The court ordered that Hughes’s complaint be dismissed without prejudice under 28 U.S.C. § 1915(e)(2)(B)(ii) for failing to adequately plead exhaustion and failing to plausibly state a Title VII claim, and under § 1915(e)(2)(B)(iii) for seeking monetary relief from individual defendants immune from that relief.

The court granted Hughes leave to file an amended complaint addressing the identified deficiencies by November 14, 2025. The court stated that failure to file an amended complaint or cure the deficiencies could lead to a recommendation that the action be dismissed with prejudice, in whole or in part. Judge information was not provided in the supplied opinion text; the signature identifies only a United States Magistrate Judge.