Norton v. ISD 197
- Donovan Frank
- 0:20-cv-01530
- U.S. District Court · District of Minnesota
- 12
In Norton v. ISD 197, Judge Frank granted the defendants’ motion, ending federal claims with prejudice and state claims without prejudice.
Larry Norton’s federal employment-discrimination claims were dismissed with prejudice, while his state-law claims against ISD 197, Ron Monson, and Melinda Weis were dismissed without prejudice.
What happened
In Norton v. ISD 197, Larry Norton alleged that ISD 197, Ron Monson, and Melinda Weis discriminated against him because of his age, race, and disability and failed to accommodate his medical condition. He said he was dismissed in June 2018.
The court ruled that Norton filed his federal claims too late after receiving a right-to-sue letter from the Equal Employment Opportunity Commission. The court also said those claims did not include enough specific facts to support discrimination claims. It declined to decide Norton’s state-law claims in federal court because all federal claims were being dismissed.
Judge Frank granted the defendants’ motion to dismiss. The court dismissed Counts I, II, and III, the federal claims, with prejudice, and dismissed Counts IV, V, VI, and VII, the state-law claims, without prejudice.
The detailed version
- Norton v. ISD 197 · No. 0:20-cv-01530
- Donovan Frank
- May 19, 2021
Background
ISD 197 hired Larry Norton in February 2018. Norton alleged that the District, principal Ron Monson, and employee Melinda Weis discriminated against him based on age, race, and disability. He also alleged that he disclosed a medical condition, requested a reasonable job adjustment, was not given the accommodation, and was dismissed in June 2018. His complaint asserted federal claims under the Age Discrimination in Employment Act, Title VII, and the Americans with Disabilities Act or related disability provisions, along with four state-law claims.
The defendants moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c), or alternatively for summary judgment. The court decided the motion under Rule 12(c). A Rule 12(c) motion tests whether the pleadings show a legally sufficient claim, using the same standard as a motion to dismiss for failure to state a claim.
Federal Claims
The court held that Norton’s federal claims were filed too late. It stated that Norton received the right-to-sue letter on or about March 20, 2020, and filed his complaint on July 7, 2020—nearly three weeks after the 90-day filing deadline. The court therefore dismissed the federal claims as time barred.
The court also ruled that the federal claims lacked sufficient factual support even if they had been timely. The complaint did not adequately explain Norton’s age, job qualifications, position, disability, or the facts connecting his termination to his age, race, or disability. It also did not identify how similarly situated employees were treated differently or provide enough facts to support a failure-to-accommodate claim. The court concluded that amending the federal claims would be futile.
State-Law Claims and Disposition
The court declined to exercise supplemental jurisdiction, which is the federal court’s authority to hear related state-law claims after federal claims are dismissed. It dismissed the state-law claims because they had the same pleading deficiencies, but it did so without prejudice.
The order granted the defendants’ Motion to Dismiss. It dismissed the federal claims in Counts I, II, and III with prejudice, and dismissed the state-law claims in Counts IV, V, VI, and VII without prejudice. The court ordered judgment to be entered accordingly.
Classification Note
This is a procedural order because the court ruled on a Rule 12(c) motion and dismissed the claims based on the filing deadline and insufficient pleading, rather than deciding whether discrimination actually occurred.
Read the full 12-page opinion on CourtListener, the free public archive maintained by the Free Law Project.