King v. Ecumenical Housing Corporation

Background

Charles Ivan King, who represented himself, sued his former employer, identified in the opinion as EAH, Inc., after the company fired him on March 9, 2017. He alleged race discrimination and retaliation under Title VII of the Civil Rights Act of 1964, disability discrimination under Title I of the Americans with Disabilities Act, breach of an employment contract, and failure to return a security deposit under California Civil Code § 1950.5(g).

King alleged that he is African American, has PTSD, and had worked as a live-in property manager. Among other allegations, he said the company did not assist him with heavy lifting after surgery, did not complete an accommodation process after he requested reassignment, and fired him before the deadline it had given him to obtain a real-estate license. He also alleged that the company retaliated after he filed a human-resources complaint.

The motion to dismiss

The defendant moved to dismiss, arguing that King had not timely pursued his federal claims before the relevant agencies or timely filed his lawsuit after receiving a right-to-sue letter. It also argued that King had not alleged enough facts to support his claims.

Under the rules governing a motion to dismiss, a complaint must provide enough factual content to make a claim plausible, rather than merely reciting legal conclusions. The court also noted that self-represented complaints are read liberally.

Federal claims

The court held that King’s federal claims were untimely. The Equal Employment Opportunity Commission’s right-to-sue letter was dated January 17, 2018, but King filed this lawsuit on September 11, 2020, more than 90 days later. The court also held that his April 10, 2018 filing with the California Department of Fair Employment and Housing was more than 300 days after his March 9, 2017 termination and therefore did not preserve his federal claims. The court rejected King’s argument that confusion about the rules and his personal circumstances changed the result.

The court separately concluded that King had not plausibly pleaded his federal claims. For the Title VII race-discrimination claim, he did not allege facts showing that similarly situated people outside his protected class were treated better. For the race-based hostile-work-environment claim, he did not allege facts connecting the workplace problems to his race. For retaliation, he did not adequately allege a causal connection between his human-resources complaint and his firing. For the Americans with Disabilities Act claim, he did not allege enough about the circumstances of his termination to show disability discrimination or denial of a reasonable accommodation.

State-law claims and disposition

Because the federal claims were not adequately before the court, the court declined to exercise supplemental jurisdiction over King’s state-law claims. Supplemental jurisdiction is a federal court’s authority to hear related state-law claims; the court may decline that authority after dismissing all claims within its original federal jurisdiction.

Judge Laurel Beeler granted the motion to dismiss. The court dismissed the federal claims as untimely, did not exercise supplemental jurisdiction over the state-law claims, and dismissed without leave to amend, finding that the federal-claim defect could not be cured by additional allegations.