McKnight v. N.A.I.C.A.

Background

Therin B. McKnight, proceeding without a lawyer, sued Neighborhood Association for Inter-Cultural Affairs, Inc. (identified in the caption as N.A.I.C.A.), Gregory Mule, and Luz Sanchez. He appeared to allege employment discrimination under Title VII and state law after his employment was terminated. The court also noted that information entered on the complaint form made it unclear whether he intended to assert claims under 42 U.S.C. § 1981 and the Age Discrimination in Employment Act of 1967.

McKnight’s complaint contained a single handwritten paragraph that was partly illegible. The court could understand that, in October 2018, Sanchez sent him to human resources after two shelter residents wrote statements about him, and that Mule and Sanchez allegedly subjected him to some form of harassment before his termination. McKnight attached an Equal Employment Opportunity Commission right-to-sue letter dated May 31, 2019, and a letter from N.A.I.C.A. dated October 25, 2018, terminating his employment. He did not attach the charges he had filed with the Equal Employment Opportunity Commission.

Motion and legal standard

The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which asks whether the complaint states a legally sufficient claim. Alternatively, they sought a more definite statement under Rule 12(e). McKnight did not respond, even after receiving three extensions and a later order requiring a response or a letter stating that he would not respond. The court decided to consider the dismissal motion rather than dismiss the action for failure to prosecute. Because it granted the Rule 12(b)(6) motion, it did not address the Rule 12(e) request.

For an employment-discrimination claim under Title VII, the court explained that a complaint must allege facts supporting an inference that the employer took adverse action at least partly for a discriminatory reason. Although courts read complaints filed without a lawyer liberally, conclusory statements and bare recitations of legal elements are not enough.

Court’s analysis

The court concluded that McKnight’s allegations did not provide fair notice of his claims. The complaint did not explain the nature of the alleged harassment, connect the alleged conduct to the termination, or show that race, color, or age was a motivating factor in the conduct or termination. Because the complaint was brief, partly illegible, and difficult to understand, the court could not determine how it stated a claim under Title VII or any other anti-discrimination statute McKnight intended to invoke.

The court separately held that McKnight’s Title VII claim, and his ADEA claim to the extent he pleaded one, against individual defendants Mule and Sanchez had to be dismissed with prejudice because individuals are not subject to liability under those statutes.

Disposition

The court granted the defendants’ motion to dismiss. McKnight’s Title VII claim and any ADEA claim against Mule and Sanchez were dismissed with prejudice. The court dismissed McKnight’s remaining claims without prejudice. It permitted him to file an amended complaint by June 13, 2020, if he had a good-faith basis to do so. The court directed the clerk to terminate the pending motion and directed the defendants to mail McKnight a copy of the order.