Knapps v. Episcopal Community Services

Background

Uganda Knapps, representing himself, sued Episcopal Community Services (ECS) under Title VII of the Civil Rights Act of 1964, alleging employment discrimination. Knapps alleged that, while working swing shifts at ECS on January 31 and February 2, 2020, a male coworker touched him on the butt while walking by. He said that after he reported both incidents to human resources, he was accused of lying and called a homophobe. Knapps checked the religion-discrimination box on the court’s employment-discrimination form, but the complaint did not identify his religion, describe his job performance, or allege how ECS treated similarly situated employees outside his protected class.

The court had granted Knapps permission to proceed without paying the filing fee. It then screened his complaint under 28 U.S.C. § 1915(e)(2), which requires the court to dismiss a fee-exempt complaint that fails to state a legally sufficient claim. The court applied the same basic standard used for a motion to dismiss for failure to state a claim: the complaint had to provide enough factual detail to make the requested relief plausible. Because Knapps was representing himself, the court read his allegations liberally, while still requiring factual support rather than conclusions.

Court’s analysis

The court explained that a Title VII employment-discrimination claim generally requires allegations that the plaintiff belongs to a protected class, performed the job satisfactorily, suffered an adverse employment action, and was treated differently from similarly situated people outside the protected class. Even giving Knapps the benefit of the doubt, the court found that his complaint did not plausibly allege that ECS acted against him because of his religion. The complaint did not state what his religion was, identify an adverse employment action based on religion, or provide facts showing different treatment of other employees.

Disposition

The court concluded that Knapps’s complaint failed the screening review. The clerk was instructed not to issue a summons or serve the complaint on ECS. Knapps was given until March 12, 2021, to file an amended complaint addressing the identified deficiencies. The order stated that, if he did not timely file an amendment or if the amended complaint remained deficient, the magistrate judge would recommend that a district judge dismiss the case. The order itself did not dismiss the case. Judge Alex Tse signed the order on February 5, 2021.