Danquah v. Target Corporation

Background

Simon Owusu Danquah alleged that he worked for Target from September 1, 2019, through December 2, 2019, and that he was treated differently during his employment because of race, national origin, or color. He alleged that Target placed him on a performance-improvement plan, that he complained to his supervisor that Caucasian employees were treated better, that the supervisor then created a hostile work environment, and that Target terminated his employment for discriminatory reasons.

Danquah sued Target Corporation and Target employees Carrie R., Jamie K., and Brian. His amended complaint asserted six counts: employment discrimination, hostile work environment, intentional infliction of emotional distress, respondeat superior, vicarious liability, and negligent hiring and retention. He relied on Title VII of the Civil Rights Act of 1964 and the Minnesota Human Rights Act for the discrimination-related claims.

Court’s analysis

The court applied the standard for a motion to dismiss for failure to state a claim. Under that standard, a complaint must allege enough facts to make the requested relief plausible, rather than merely possible or speculative. The court accepts well-pleaded factual allegations as true but does not accept legal conclusions presented as facts.

Count I: Employment discrimination. The court dismissed Danquah’s race-discrimination claims under Title VII and the Minnesota Human Rights Act. The court concluded that Danquah did not allege his race, national origin, or color in the amended complaint; did not allege facts showing that he met Target’s legitimate performance expectations; and did not allege enough facts to support an inference that discrimination caused the discipline or termination. Although termination was an adverse employment action, the court found that the other required allegations were insufficient.

Count II: Hostile work environment. The court dismissed this count because the amended complaint did not plausibly allege severe and pervasive harassment based on a protected status. Danquah alleged that a female manager blamed him for mistakes he did not make and used general descriptions such as “hostile” and “toxic” working conditions. The court found those allegations too conclusory and insufficient to show a hostile work environment under Title VII or the Minnesota Human Rights Act.

Count III: Intentional infliction of emotional distress. The court dismissed this claim as preempted by the Minnesota Human Rights Act. The court found that the claim relied on the same alleged injuries as the discrimination and hostile-work-environment claims and involved the same practical obligation owed by Target.

Counts IV and V: Respondeat superior and vicarious liability. The court dismissed these counts because respondeat superior and vicarious liability are theories of liability, not independent claims for relief. The court stated that such theories could potentially apply while litigating a viable discrimination or hostile-work-environment claim, but Danquah had not plausibly pleaded those underlying claims.

Count VI: Negligent hiring and retention. The court dismissed this claim as preempted by the Minnesota Human Rights Act because Danquah based it on the same injuries and did not explain how its factual basis differed from his discrimination and hostile-work-environment claims. The court also noted that, even without preemption, Danquah had not alleged a physical injury, which the court identified as a requirement for the claim.

Disposition

Judge Wilhelmina M. Wright granted the defendants’ motion to dismiss. The court dismissed all counts of the amended complaint without prejudice. Because all claims were dismissed for failure to state a claim, the court did not address the defendants’ alternative motion for a more definite statement. The order directed that judgment be entered accordingly.