West v. At Home Stores LLC

Background

Jonathan West went to an At Home store in Burnsville, Minnesota, on May 19, 2019, to return items. West, who is African American, alleged that a white female cashier instructed him to wait in line. He waited, returned the items, and received store merchandise credit. West later alleged that the same cashier allowed a white female customer who had entered the store to skip the line to return items.

West sued under the Minnesota Human Rights Act, claiming race and sex discrimination in a place of public accommodation. Although he was not denied services altogether, he alleged that he was denied the full and equal enjoyment of the store’s goods, services, facilities, privileges, advantages, and accommodations. He sought damages for mental anguish and suffering, as well as other damages, costs, and attorney’s fees.

Legal standard and analysis

At Home moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not allege enough facts to make a claim legally plausible. The court accepted plausible factual allegations as true but did not accept unsupported conclusions.

The court explained that an actionable Minnesota Human Rights Act claim requires some tangible change in conditions or material disadvantage. It rejected West’s argument that his alleged humiliation was enough under the circumstances. The court reasoned that standing in line was not embarrassing or a material disadvantage that denied him full and equal enjoyment of the store. It also stated that West’s allegations showed he received the same treatment as customers in line and that a customer could reasonably expect an employee to instruct him to wait in line.

The court characterized the alleged harm as perceived harm or hurt feelings rather than an actionable injury. It further held that, accepting the complaint’s facts as true, it could not plausibly infer a discriminatory motive based on race or sex. The complaint’s conclusion that At Home’s conduct amounted to racial or sex-based profiling and discrimination was insufficient.

Disposition

The court granted At Home Stores LLC’s motion to dismiss and dismissed the matter with prejudice. The court also directed that judgment be entered accordingly. Judge Paul A. Magnuson signed the memorandum and order.