Taylor v. Childrens Village

Background

Tara Reshay Patrick Taylor proceeded without a lawyer and filed the action without paying the filing fee. After Judge Louis L. Stanton directed her to address deficiencies in her original complaint, Taylor filed an amended complaint.

The amended complaint used an employment-discrimination form and included allegations concerning religion, disability, retaliation, domestic violence, human trafficking, and sex trafficking. Taylor identified her religion as “Christianity (Spirituality)” and described her disability or perceived disability as “[b]ipolar, schizophrenia, sleeping on duty.” She also alleged discrimination related to anemia and said she sought an accommodation so she would not appear to be sleeping. The complaint stated that her employment was terminated after counseling summaries concerning workplace incidents, including leaving youth unsupervised, allowing two youth to leave a facility, and sleeping on duty.

Court’s analysis

The court applied the screening requirement for complaints filed without paying the filing fee. Under that rule, the court must dismiss claims that are frivolous, malicious, fail to state a claim for relief, or seek money from an immune defendant. The court also explained that self-represented pleadings are read liberally, but they still must provide enough factual detail to make a claim plausible.

For the Title VII religious-discrimination claims, the court held that Taylor’s only religion-related allegation—that she was retaliated against, harassed, and intimidated because she would not participate in unspecified activities outside work—was too vague. Taylor did not describe those activities or allege facts connecting her religion to her treatment or termination. The court therefore dismissed the religious-discrimination claims for failure to state a claim.

The court treated the Americans with Disabilities Act and Rehabilitation Act claims under generally the same standards for this order. It held that Taylor did not allege facts showing that anemia substantially limited a major life activity. It also held that she did not identify the accommodation she requested or provide facts showing that the request was reasonable or that she could perform the job’s essential functions with or without an accommodation. As to alleged mental-health disabilities, the court assumed, for purposes of its analysis, that they could qualify as disabilities but found no facts suggesting that the employer took adverse action because of them. The court dismissed the ADA and Rehabilitation Act claims for failure to state a claim.

The court held that being a survivor of domestic violence or human trafficking is not a protected class under Title VII. It separately considered Taylor’s reference to the Trafficking Victims Protection Reauthorization Act, which allows certain victims of forced labor or trafficking to bring civil claims. The court found that Taylor did not allege facts showing that her former employer subjected her to forced labor in violation of that statute.

Disposition

Judge Cathy Seibel dismissed Taylor’s amended complaint under 28 U.S.C. § 1915(e)(2)(B)(ii). After dismissing the federal claims, the court declined to exercise supplemental jurisdiction—the authority to hear related state-law claims—over any state-law claims Taylor might be asserting. The court declined to grant leave to amend again because Taylor had already amended once, had not requested another amendment, and had not indicated what additional facts would cure the deficiencies.

The court denied Taylor’s motion to compel as moot. It also certified that any appeal would not be taken in good faith and denied her status allowing her to appeal without paying the filing fee.