Jaiyeola v. Apple, Inc

Background

Ganiyu Ayinla Jaiyeola represented himself in a lawsuit against his former employer, Apple, Inc. He worked for Apple as a Senior Subject Matter Expert from February 21, 2022, until Apple terminated his employment on August 8, 2023. His first amended complaint asserted six claims under 42 U.S.C. § 1981, Title VII, and the California Fair Employment and Housing Act. The claims concerned alleged race and national-origin discrimination, hostile work environment harassment, and retaliation.

Jaiyeola identified himself as African American, Black, and Nigerian. He alleged that Apple employees made negative comments about his work, treated him differently, denied him a performance bonus, gave him a below-expectation rating, pressured him about complaints to Apple’s Equal Employment Opportunity office, and excluded him from a meeting attended by employees of other racial or national backgrounds. He also alleged that Apple placed him on a performance-coaching plan in July 2023 and terminated him for failing to meet its requirements. Jaiyeola alleged that he had filed multiple internal discrimination complaints before his termination.

Requests for judicial notice

Jaiyeola asked the court to take judicial notice of a separate lawsuit he had filed involving Apple and other defendants. The court denied that request because the other lawsuit involved different facts and causes of action and was not related litigation for purposes of judicial notice.

Jaiyeola also asked the court to take judicial notice of a $25 million settlement between Apple and the U.S. Department of Justice concerning alleged discrimination in Apple’s hiring practices. The court granted that request as to the settlement’s existence as a public document, but it did not accept disputed facts in the settlement as established facts.

Motion to dismiss

Apple moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint alleges enough facts to state a legally plausible claim. The court explained that a complaint must give the defendant fair notice of the alleged wrongdoing and must include factual allegations supporting a plausible entitlement to relief. The court also recognized that self-represented pleadings receive a less demanding reading, but still must provide sufficient notice of the claims.

For Counts I through V, involving discrimination claims under Section 1981, Title VII, and the California Fair Employment and Housing Act, the court held that Jaiyeola had not alleged facts connecting Apple’s employment actions to his race or national origin. The court found that the alleged remarks, the meeting involving employees of other racial or national backgrounds, and allegations concerning other Apple employees did not, without more, support an inference that Apple discriminated against Jaiyeola because of his race or nationality. The court also held that the Department of Justice settlement concerning hiring discrimination did not establish discrimination against Jaiyeola during his employment based on race or Nigerian nationality. The court therefore granted Apple’s motion to dismiss Counts I–V.

For Count VI, alleging retaliation under the California Fair Employment and Housing Act, the court held that Jaiyeola had not alleged facts showing a causal connection between his internal complaints and an adverse employment action. The court noted that Jaiyeola alleged multiple complaints against several employees but did not identify facts linking those complaints to his termination or another adverse action. The allegations that employees pressured him not to file or to withdraw complaints also lacked details about the pressure, any threats or statements, the complaint involved, or how the conduct constituted an adverse employment action. The court therefore granted Apple’s motion to dismiss Count VI.

Leave to amend and final disposition

Jaiyeola asked for permission to file a second amended complaint. The court explained that leave to amend is generally allowed when justice requires, but may be denied when amendment would be futile or when prior amendments have not cured the deficiencies. The court had previously identified similar deficiencies in orders concerning Jaiyeola’s requests for temporary restraining orders, had allowed him to file the first amended complaint, and had warned him that future amendments required permission or Apple’s consent.

The court reviewed the proposed second amended complaint and found that it largely repeated the first amended complaint’s allegations. The additional allegations about Jaiyeola’s experience, education, job performance, and colleagues’ abilities still did not establish a connection between the alleged conduct and his race or nationality or between the alleged retaliation and his complaints. The court therefore denied Jaiyeola’s motion for leave to file an amended complaint.

The court’s conclusion states that it granted Apple’s motion to dismiss and denied Jaiyeola’s motion for leave to amend. It dismissed the case with prejudice, instructed the Clerk of Court to close the file, and entered the order on March 27, 2024.