Aha v. Minnesota Veteran Home

Background

Shakur Aha sued the Minnesota Veterans Home and the Minnesota Department of Veterans Affairs. He represented himself. Aha alleged that, while employed at the Minnesota Veterans Home, he was assaulted by the head of security and other coworkers; discriminated against by supervisors because of his ethnic background; subjected to emotional distress through racial slurs; libeled through untruthful performance reviews; and slandered through statements about his sexual orientation and history of personal abuse. He sought $50 million for pain and suffering and $100 million in punitive damages.

The complaint asserted six types of claims: assault, employment discrimination under Title VII of the Civil Rights Act of 1964, intentional infliction of emotional distress, libel, slander, and damage to reputation. The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(1), which concerns subject-matter jurisdiction, and Rule 12(b)(6), which concerns failure to state a legally sufficient claim.

Court’s Analysis

The court treated the tort claims—assault, intentional infliction of emotional distress, libel, slander, and damage to reputation—as barred by the Eleventh Amendment. That constitutional provision generally prevents states and their agencies from being sued in federal court without consent. The court determined that the Minnesota Veterans Home and Minnesota Department of Veterans Affairs were executive-branch agencies of Minnesota and found no indication that Minnesota had consented to these tort claims. It therefore concluded that the tort claims had to be dismissed under Rule 12(b)(1).

The court treated Aha’s discrimination claim as a claim under Title VII. It explained that Title VII permits states to be sued, so the Eleventh Amendment did not eliminate federal jurisdiction over that claim. But before bringing a Title VII lawsuit, an employee must complete the required administrative process, including filing a timely charge and receiving a right-to-sue letter. Although Aha stated in his response that he had filed with the Equal Employment Opportunity Commission, his amended complaint did not allege that he had completed the process. The court found no evidence that he had received a right-to-sue letter and noted that Aha conceded he had not yet obtained one.

Disposition

The court held that dismissal of the Title VII claim was warranted because Aha had not shown that he completed the required administrative process. On March 19, 2021, Judge Michael J. Davis ordered that the defendants’ motion to dismiss was granted and that the matter was dismissed without prejudice. The opinion does not separately state a different disposition for each individual claim beyond that final order.