Strickland v. DeJoy
- Alex Tse
- 3:25-cv-05212
- U.S. District Court · Northern District of California
- 2
In Strickland v. DeJoy, Judge Chesney granted DeJoy’s dismissal motion, dismissed the complaint, and allowed amendment because timely administrative exhaustion was not adequately alleged.
Shamika Strickland’s claims against Louis DeJoy under the Americans with Disabilities Act and the Rehabilitation Act.
What happened
In Shamika Strickland v. Louis DeJoy, Postmaster General, Strickland challenged decisions about her workplace accommodation requests under the Americans with Disabilities Act and the Rehabilitation Act.
Strickland said she was not pursuing the Americans with Disabilities Act claims and was not seeking punitive damages, so the court granted those parts of the motion as unopposed. The court also found that her Rehabilitation Act claims did not allege that she timely contacted an Equal Employment Opportunity Commission counselor.
Judge Chesney granted the motion to dismiss and dismissed the complaint, but allowed Strickland to file an amended complaint by January 30, 2026, if she could allege timely exhaustion and other supporting facts. The court also vacated the January 9, 2026 hearing.
The detailed version
- Strickland v. DeJoy · No. 3:25-cv-05212
- Alex Tse
- Dec. 29, 2025
Background
Shamika Strickland brought claims under the Americans with Disabilities Act and the Rehabilitation Act based on alleged government decisions concerning her requests for accommodations at her workplace. Louis DeJoy moved to dismiss the complaint. The parties submitted written briefing, and the court decided the motion without holding the scheduled January 9, 2026 hearing.
Court’s Analysis
Strickland stated in her opposition that she did not seek relief under the Americans with Disabilities Act and did not seek punitive damages. The court therefore granted the motion as unopposed to the extent it sought dismissal of those claims or relief.
The court held that Strickland’s Rehabilitation Act claims were subject to an administrative-exhaustion requirement. Under the cited regulation, a person alleging disability discrimination must contact an Equal Employment Opportunity Commission counselor within 45 days of the alleged discriminatory matter. The court noted that this requirement applies to failure-to-accommodate claims brought under the Rehabilitation Act.
Although Strickland stated that she had submitted an Equal Employment Opportunity Commission complaint and provided an order dismissing it, she did not allege when she first contacted an Equal Employment Opportunity Commission counselor or identify the claim or claims raised at that time. The court therefore found that the complaint did not establish timely exhaustion. Because of that ruling, the court did not reach DeJoy’s alternative argument that the complaint lacked enough facts to support a Rehabilitation Act claim. The court also stated that DeJoy’s argument concerning lost wages was not supported by the document on which DeJoy relied.
Disposition
Judge Maxine M. Chesney granted DeJoy’s motion to dismiss and dismissed the complaint. The dismissal was with leave to amend: Strickland could file a First Amended Complaint alleging facts establishing timely exhaustion of her Rehabilitation Act claims and adding other facts supporting those claims. The deadline was January 30, 2026. The court also vacated the January 9, 2026 hearing.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.