Goddard v. Slickdeals

Background

Thomas Joseph Goddard, proceeding without a lawyer, sued Slickdeals, LLC and Apple, Inc. for discrimination and related claims. He alleged that Apple offered him a Senior Software Engineer position in September 2023 but rescinded the offer on October 24, 2023. He attributed the decision to discrimination based on his race and religion, among other allegations. He also alleged that Slickdeals discriminated against him, retaliated after he made a whistleblower complaint, denied disability accommodations, and terminated his employment on July 15, 2024.

Goddard filed a discrimination charge with the Equal Employment Opportunity Commission on March 18, 2025. The agency issued a dismissal and notice of rights on May 8, 2025. He then sued Slickdeals and Apple. After Goddard filed an amended complaint that he did not serve on Apple, Apple moved to dismiss the claims against it. Goddard moved for permission to file a second amended complaint.

Apple’s Motion to Dismiss

The court granted Apple’s request to take judicial notice of a state-court complaint and a California Civil Rights Department letter. The court took notice of the existence of allegations in the state-court complaint, not the truth of disputed facts in that document.

The court dismissed Goddard’s Title VII pattern-or-practice claim under 42 U.S.C. § 2000e-6 without leave to amend. It held that this provision authorizes the Attorney General or the Equal Employment Opportunity Commission to bring a pattern-or-practice action, not a private individual.

The court dismissed Goddard’s Title VII race-and-religion claim. It held that, based on the allegations in the complaint, he did not timely exhaust the required administrative process before filing suit. The court also held that, even if he had exhausted that process, he did not plausibly allege that race or religion was a motivating factor in Apple’s decision to rescind the job offer. The court granted leave to amend this claim only if Goddard could allege, in good faith, that he timely exhausted his administrative remedies.

The court dismissed the claim under 42 U.S.C. § 1981, which prohibits race discrimination in making and enforcing contracts, with leave to amend. The court held that Goddard did not plausibly allege that race was the reason Apple rescinded the offer or that he would have been hired but for race discrimination.

The court dismissed the Fair Credit Reporting Act claim with leave to amend. Although Goddard alleged that Apple relied on background-check information, he did not allege that Apple relied on a “consumer report” or information from a consumer-reporting agency, which the statute requires for the notice obligations at issue.

The court dismissed the California Unfair Competition Law claim with leave to amend. Goddard did not plausibly identify an unlawful, fraudulent, or unfair business practice by Apple or a separate law that Apple violated. His fraud allegations also did not satisfy Federal Rule of Civil Procedure 9(b), which requires fraud to be pleaded with particular details such as what was false, who made the statement, when it was made, and why it was false. The court dismissed the fraud claim with leave to amend.

The court dismissed the intentional-infliction-of-emotional-distress claim with leave to amend. It held that Goddard’s conclusory allegations did not plausibly show that Apple’s conduct was extreme and outrageous.

Claims Against Slickdeals

The court dismissed Goddard’s claims against Slickdeals without prejudice to pursuing them in a separate lawsuit. It concluded that the claims against Slickdeals arose from his employment and alleged retaliation and discrimination between October 2023 and July 2024, while the claims against Apple arose from Apple’s October 24, 2023 rescission of his job offer. The court found that the claims did not arise from the same transaction or occurrence and did not present common questions of law or fact sufficient to join the defendants in one action.

Motion for Leave to Amend and Disposition

The court denied Goddard’s motion for leave to file a second amended complaint because the proposed complaint repeated several defects identified in the order, making amendment futile. The court noted that it had already allowed him to file a first amended complaint consistent with the order.

The court granted Apple’s motion to dismiss. The dismissal of the Title VII pattern-or-practice claim was without leave to amend. Goddard was allowed to amend his other claims against Apple subject to the conditions stated in the order, including that he could not add new defendants or claims without further permission. The court stated that any claims against Slickdeals must be presented in a separate complaint. The deadline to file an amended complaint against Apple was November 21, 2025; if no amended complaint was filed by then, judgment would be entered in Apple’s favor on all claims.