Cain v. Mercy College

Background

Ileen Cain sued Mercy College and other defendants, alleging discrimination based on race, disability, and gender under Title VI of the Civil Rights Act of 1964, the Rehabilitation Act, the Americans with Disabilities Act, and Title IX of the Education Amendments of 1972. The court had previously granted Cain leave to file an amended complaint and instructed her to provide enough facts to support her claims. The court concluded that the amended complaint repeated the same basic allegations without supplying facts showing discrimination based on race, disability, or gender.

Cain alleged that she had reported cyberstalking, stalking, and sexual harassment to college officials. She also alleged that college personnel contacted classmates with questions about whether she was threatening or unstable, which she said led to fear, embarrassment, poor grades, and students tormenting her. She claimed that a D grade was retaliation for her complaints, but a hearing committee determined that the grade was justified. She also alleged that a Title IX coordinator offered information about stalking centers and that the college’s general counsel referred her to counseling services.

Court’s Analysis

The court applied the screening standard for complaints filed without paying the filing fee. Under 28 U.S.C. § 1915(e)(2)(B), the court must dismiss such a complaint if it is frivolous or malicious, fails to state a claim, or seeks relief from an immune defendant. The court also must dismiss when it lacks subject-matter jurisdiction. Although the court must read complaints filed without a lawyer generously, the complaint still must provide enough factual detail to make a claim plausible.

For the Title VI claim, the court held that Cain alleged no facts suggesting that any defendant discriminated against her because of race, color, or national origin. The court therefore dismissed the Title VI claim for failure to state a claim.

For the Americans with Disabilities Act claim, the court assumed, for purposes of its analysis, that Cain was disabled but found no allegation that the defendants’ conduct was motivated by her disability. The court said the allegations instead suggested a disagreement about coursework. For the Rehabilitation Act claims, Cain did not allege that she was excluded from her education solely because of a disability or that disability-based harassment created an abusive educational environment. The court dismissed both the Americans with Disabilities Act and Rehabilitation Act claims for failure to state a claim.

For the Title IX claims, the court held that Cain did not allege that male students in similar circumstances were treated more favorably or that the defendants treated her differently because she is a woman. The court dismissed the Title IX claims for failure to state a claim.

Disposition

The court declined to grant further leave to amend because Cain had already been given an opportunity to correct the complaint’s deficiencies and the court concluded that those deficiencies could not be cured by another amendment. After dismissing the federal claims, the court declined to exercise supplemental jurisdiction over any state-law claims Cain may have been asserting. Judge Louis L. Stanton directed the Clerk to mail the order to Cain, note service on the docket, and terminate any motions. The amended complaint was dismissed under 28 U.S.C. § 1915(e)(2)(B)(ii).