Williams v. U.S. Airways American Airlines, Inc.

Background

Anthony L. Williams alleged that American Airlines did not hire him as a mechanic because of his race and age. His complaint asserted claims under the California Fair Employment and Housing Act (FEHA). He applied for the position in July 2015, contacted the Equal Employment Opportunity Commission (EEOC), filed an EEOC charge, and received an EEOC notice giving him permission to sue in June 2017.

Williams had previously filed a similar action involving the same employment allegations. That action was dismissed for failure to prosecute, and the dismissal was later modified to state that it was without prejudice. Williams then filed the present action in California state court in May 2018. After Williams properly served American Airlines in November 2019, American Airlines removed the case to federal court based on diversity jurisdiction. Williams moved to remand, and American Airlines moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c).

Motion to Remand

The court denied the motion to remand. It held that diversity jurisdiction existed because Williams was a California citizen, while American Airlines was incorporated in Delaware and had its principal place of business in Texas. The court rejected Williams’s argument that American Airlines was also a California citizen because it paid taxes and conducted operations there.

The court also found that the amount in controversy exceeded $75,000. The complaint sought back pay, future lost earnings, emotional-distress damages, and punitive damages. Based on the mechanic position’s stated pay and the damages sought, the court concluded that American Airlines had shown it was more likely than not that the amount in controversy exceeded the jurisdictional threshold. The court also found that removal was timely. It therefore denied Williams’s motion to remand.

Judgment on the Pleadings

The court granted American Airlines’ motion for judgment on the pleadings. This type of motion asks whether, accepting the complaint’s properly pleaded factual allegations as true, the pleadings show that the moving party is entitled to judgment as a matter of law.

The court agreed that Williams had not exhausted the administrative process required for FEHA claims. Exhaustion meant, in this context, timely pursuing the administrative claims and obtaining a right-to-sue notice from the California Department of Fair Employment and Housing (DFEH). The complaint included an EEOC charge and an EEOC right-to-sue notice, but Williams did not show that he received a right-to-sue notice from the DFEH. The court held that an EEOC right-to-sue notice did not satisfy the exhaustion requirement for FEHA claims.

The court separately considered whether the complaint might be read to assert federal claims under statutes including Title VII of the Civil Rights Act and the Age Discrimination in Employment Act. It concluded that any such federal claims were time-barred because they were not filed within 90 days after the EEOC right-to-sue notice. The court also concluded that equitable tolling, equitable estoppel, and laches did not preserve those claims. Because the complaint specifically asserted FEHA claims and Williams had not established FEHA exhaustion, while any federal claims were untimely, the court granted American Airlines’ motion for judgment on the pleadings.

Disposition

The court denied Williams’s motion to remand and granted American Airlines’ motion for judgment on the pleadings. The order disposed of Docket Nos. 16 and 19.