Mejia v. White Plains Self Storage Corp
- Kenneth Karas
- 7:18-cv-12189
- U.S. District Court · Southern District of New York
- 15
In Mejia v. White Plains Self Storage Corp., Judge Karas granted the employer’s motion to dismiss religious-discrimination claims without prejudice, allowing amendment.
The ruling affected Walter D. Mejia’s federal, New York State, and New York City religious-employment-discrimination claims against White Plains Self Storage Corp.; all were dismissed without prejudice, subject to his opportunity to amend within 30 days.
What happened
Walter D. Mejia sued White Plains Self Storage Corp., alleging that it discriminated against him because of his religion, retaliated against him, and created a hostile work environment after he raised concerns about Sunday scheduling. He brought claims under federal, New York State, and New York City employment-discrimination laws.
The court dismissed the New York City claim because the alleged workplace conduct occurred in White Plains, not New York City. It dismissed the New York State claim because Mejia had already pursued the same allegations before the New York State Division of Human Rights. It also dismissed the federal claims because the complaint did not provide enough facts about his religion, requested accommodation, possible comparators, protected complaint, or religious harassment.
Judge Kenneth M. Karas granted the motion to dismiss without prejudice because this was the first adjudication of the claims on the merits. Mejia was allowed 30 days to file an amended complaint addressing the identified deficiencies; the court warned that failure to meet the deadline could lead to dismissal with prejudice.
The detailed version
- Mejia v. White Plains Self Storage Corp · No. 7:18-cv-12189
- Kenneth Karas
- Jan. 16, 2020
Background
Walter D. Mejia, proceeding without a lawyer, sued White Plains Self Storage Corp. He alleged that the company hired him in June 2017 with an agreement to provide a religious accommodation. After he emailed supervisors on September 30, 2017, expressing concern about being scheduled on Sundays, he alleged that he was treated differently, written up unfairly, and terminated on November 25, 2017.
Mejia asserted religious-discrimination, retaliation, and hostile-work-environment claims under Title VII of the federal Civil Rights Act, the New York State Human Rights Law, and the New York City Human Rights Law. The defendant moved to dismiss under Federal Rules of Civil Procedure 12(b)(1), which concerns the court’s subject-matter jurisdiction, and 12(b)(6), which concerns whether a complaint states a legally sufficient claim. Mejia did not oppose the motion.
The complaint included a New York State Division of Human Rights determination finding no probable cause and stating that there was insufficient evidence connecting the termination decision to Mejia’s religion. It also included an Equal Employment Opportunity Commission notice stating that the federal agency had adopted the state agency’s findings. The court declined to consider additional texts and emails Mejia filed before the motion because they were not attached to or incorporated into the complaint and were largely unrelated to the religious-discrimination allegations.
Court’s Analysis
New York City claim. The court held that the New York City Human Rights Law did not apply because Mejia alleged that the discriminatory events occurred at his workplace in White Plains and did not allege that the impact of the conduct occurred within New York City. The court noted that Mejia lived in the Bronx but concluded that residence alone did not establish that the New York City law applied.
New York State claim. The court held that it could not reconsider Mejia’s New York State Human Rights Law claim because he had already filed the same claim with the New York State Division of Human Rights. The state agency had dismissed the claim on the merits rather than for administrative convenience, so the court concluded that it lacked authority to hear the claim again.
Federal discrimination claim. The court concluded that Mejia had not alleged enough specific facts to make a federal religious-discrimination claim plausible. The complaint did not identify the religion involved, explain the scope of the requested accommodation, describe statements or actions showing discriminatory intent, or identify similarly situated employees who received better treatment.
Federal retaliation claim. The court concluded that the complaint did not plausibly allege protected activity. Mejia alleged only that he emailed supervisors about being scheduled on Sundays. The court found that this did not sufficiently show that he complained about discrimination based on religion, rather than complaining generally that the company was not honoring an alleged scheduling understanding. Because the claim failed at this initial requirement, the court did not address the other retaliation elements, including causation.
Hostile-work-environment claim. The court dismissed any hostile-work-environment claim because Mejia did not allege even one instance of religious harassment involving him or a coworker. The court explained that such a claim requires conduct that is severe or pervasive enough to create an objectively hostile or abusive workplace and is connected to the plaintiff’s protected status.
Disposition
Judge Kenneth M. Karas granted the defendant’s motion to dismiss. The dismissal was without prejudice because this was the first adjudication of Mejia’s claims on the merits. The court allowed Mejia 30 days from the date of the Opinion and Order to file an amended complaint. The court stated that an amended complaint would replace, rather than supplement, the original complaint and warned that failure to meet the deadline could result in dismissal with prejudice. The Clerk was directed to terminate the pending motion.
Read the full 15-page opinion on CourtListener, the free public archive maintained by the Free Law Project.