Moody v. U.S. Equal Employment Opportunity Commission

Background

Aura Moody, proceeding without a lawyer, sued the U.S. Equal Employment Opportunity Commission (EEOC) and EEOC officials Luis Calzada, William Sanchez, Madeline McGrath, and Alexander Adeshchenko. The suit concerned the EEOC’s handling of discrimination charges Moody filed against the New York City Department of Education and the Union Federation of Teachers.

Moody alleged that the Department of Education denied or failed to process requests for medical and religious exemptions from a COVID-19 vaccination requirement and for remote work. She alleged that she was placed on leave and later terminated. She filed charges with the EEOC alleging disability and religious discrimination and retaliation. The EEOC issued right-to-sue letters after declining to pursue the charges, and Moody sought reconsideration from EEOC officials.

Her complaint asserted claims under Title VII, the Americans with Disabilities Act, the Age Discrimination in Employment Act, the Rehabilitation Act, 42 U.S.C. § 1981, the First and Fourteenth Amendments, the Health Insurance Portability and Accountability Act, and several state laws. She also asserted breach of contract and sought damages, punitive damages, and injunctive relief, including reinstatement and accommodations.

Rulings on Injunctive Relief

The court dismissed any claims seeking an order requiring the EEOC or the individual defendants to reinstate Moody, provide back pay, or provide accommodations. The EEOC was not Moody’s employer and therefore could not reinstate her or provide back pay. The New York City Department of Education was not a party to the case, so the court could not order it to act.

Federal Employment-Discrimination Claims

The court held that the United States had not waived its protection from lawsuits seeking damages against the EEOC for allegedly mishandling a discrimination charge. It therefore dismissed Moody’s Title VII, Americans with Disabilities Act, Age Discrimination in Employment Act, and Rehabilitation Act claims against the EEOC for lack of subject-matter jurisdiction.

The court dismissed those same claims against the individual EEOC defendants for failure to state a claim because those statutes do not impose personal liability on individual officials.

Section 1981 Claims

The court dismissed Moody’s 42 U.S.C. § 1981 claims against the EEOC for lack of subject-matter jurisdiction because the United States had not waived its protection from such claims. It dismissed the claims against the individual defendants for failure to state a claim because the court treated them as federal officials, while Section 1981 applies only to state actors.

Constitutional Claims

The court dismissed Moody’s First and Fourteenth Amendment damages claims against the EEOC for lack of subject-matter jurisdiction. The EEOC is a federal agency, and the United States had not waived its protection from these claims.

The court also dismissed the constitutional claims against the individual defendants for failure to state a claim. The court concluded that the type of constitutional lawsuit Moody sought was not available in this context and that she had another potential remedy because she could sue her employer directly for discrimination.

HIPAA Claims

The court dismissed Moody’s Health Insurance Portability and Accountability Act claims against the EEOC for lack of subject-matter jurisdiction because the United States had not waived its protection from such claims. It dismissed the claims against the individual defendants for failure to state a claim because HIPAA does not give individuals a private right to sue. The court also stated that Moody had not alleged that the EEOC disclosed her medical information or otherwise violated HIPAA.

Breach of Contract

The court understood Moody’s contract claim to concern a collective bargaining agreement between the New York City Department of Education and the Union Federation of Teachers. Because neither the EEOC nor the individual defendants was a party to that agreement, the court dismissed Moody’s contract claims against them for failure to state a claim. The court stated that, to the extent Moody sought more than $10,000 from the federal government on a non-tort contract claim, the district court also lacked jurisdiction over that request.

State-Law Claims and Disposition

After dismissing the federal claims, the court declined to exercise supplemental jurisdiction over Moody’s claims under New York law. The court dismissed those state-law claims without prejudice.

The court’s conclusion specified these dispositions: the motion to dismiss was granted; Moody’s claims against the EEOC under Title VII, the Americans with Disabilities Act, the Age Discrimination in Employment Act, the Rehabilitation Act, Section 1981, the First and Fourteenth Amendments, HIPAA, and state law were dismissed without prejudice; her breach-of-contract claim against the EEOC was dismissed with prejudice; her claims against the individual defendants under the listed federal laws and for breach of contract were dismissed with prejudice; and her state-law claims against the individual defendants were dismissed without prejudice. Judge Ronnie Abrams directed the Clerk of Court to terminate the pending motion and close the case.