Jaiyeola v. Rivian

Background

Ganiyu Ayinla Jaiyeola applied for an engineering position with Rivian in April 2020 and was interviewed by video and telephone. Rivian informed him on June 24, 2020, that it would not hire him. Jaiyeola alleged that the decision was based on his race and national origin.

Jaiyeola filed charges with the Michigan Department of Civil Rights and the Equal Employment Opportunity Commission. The Michigan agency dismissed his charge for insufficient evidence, and the Equal Employment Opportunity Commission adopted that finding and issued a notice of his right to sue. Jaiyeola then filed this action asserting claims under Title VII and Michigan’s Elliot-Larsen Civil Rights Act (ELCRA).

Rivian moved to dismiss. It argued that venue was improper for the Title VII claim under Federal Rule of Civil Procedure 12(b)(3), and that both claims failed to state a legally sufficient claim under Rule 12(b)(6). Rivian alternatively asked the court to transfer the case to the Eastern District of Michigan. The opinion describes Jaiyeola as representing himself.

Title VII Venue Ruling

Title VII has special venue rules. A discrimination case may generally be filed in a district where the alleged unlawful employment practice occurred, where the relevant employment records are maintained and administered, or where the person would have worked but for the alleged discrimination.

The court found that Jaiyeola did not establish venue in the Northern District of California under any of these alternatives. The employment decision was made by a hiring manager in Rivian’s Plymouth, Michigan, location, and Jaiyeola was living in Michigan when the decision was made. The fact that some interviewers may have been in California did not establish that the hiring decision was made there or that its effects were felt there.

The court also found no evidence that the relevant employment records were maintained and administered in the Northern District of California. Even accepting Jaiyeola’s allegations about a possible server location, those allegations pointed to Irvine, which is in the Central District of California, not the Northern District. Finally, the court found that the position appeared to have been based in Plymouth, Michigan; even Jaiyeola’s contention that he would have worked in Irvine would not establish venue in the Northern District.

The court therefore granted Rivian’s motion to dismiss the Title VII claim for improper venue. It dismissed that claim without prejudice to refiling the action in a district where venue is proper under 42 U.S.C. § 2000e-5(f)(3). The court did not reach whether Jaiyeola adequately stated a Title VII discrimination claim.

ELCRA Pleading Ruling

The parties appeared to agree that Jaiyeola’s ELCRA claim was governed by the elements of a basic Title VII discrimination case. Those elements required allegations that Jaiyeola belonged to a protected class, applied for and was qualified for the position, was rejected despite his qualifications, and that Rivian either filled the position with someone outside his class or continued considering similarly qualified applicants after rejecting him.

The court found that the complaint did not allege facts supporting the latter three elements. Specifically, it did not allege that Jaiyeola was qualified, that Rivian rejected him despite those qualifications, or that Rivian filled the position with someone outside his class or continued considering comparable applicants. The court declined to rely on facts in Jaiyeola’s declaration because they were outside the complaint and were not appropriate for consideration on the motion to dismiss.

The court granted Rivian’s motion to dismiss for failure to state a claim as to the ELCRA claim. It dismissed that claim without prejudice and granted leave to amend. Jaiyeola was required to file an amended complaint within 21 days, and could not add new parties or claims without court approval or Rivian’s stipulation.

Other Rulings and Disposition

The court granted both sides’ requests for judicial notice of specified public documents, while declining to treat disputed factual matters in those documents as established facts.

Judge Beth Labson Freeman’s order granted Rivian’s motion to dismiss Jaiyeola’s Title VII claim for improper venue and granted as to the ELCRA claim Rivian’s motion to dismiss for failure to state a claim. The Title VII claim was dismissed without prejudice to refiling in a proper district, and the ELCRA claim was dismissed without prejudice with leave to amend within 21 days. The court did not decide the merits of whether Rivian discriminated against Jaiyeola.