Joyner v. Alston & Bird LLP

Background

Dawn M. Joyner, representing herself, sued Alston & Bird LLP, Richard Hays, Cathy Benton, and Michael Stevens. The complaint alleged claims under Title VII of the Civil Rights Act of 1964, 42 U.S.C. §§ 1983 and 1985(3), and the Privacy Act of 1974. The allegations included claims concerning payroll-tax withholding, religious discrimination, and alleged violations of due process and equal protection.

The defendants had filed a motion to dismiss the complaint. Judge Analisa Torres referred that motion to Judge Cave for a report and recommendation, and the motion to dismiss was still pending when this order was issued.

Motions at Issue

Joyner previously filed a motion asking the court to take mandatory judicial notice of Federal Rules of Civil Procedure and Evidence, case citations, and dictionary definitions. The court denied that motion without prejudice, meaning Joyner could renew the request later if she identified facts that qualified for judicial notice.

Joyner then filed a Motion for Clarification. She argued that Federal Rule of Evidence 201 allows judicial notice at any stage of a proceeding. She also argued that the defendants’ motion to dismiss should be denied because it did not include supporting affidavits. Joyner separately filed a Proposed Order that would have denied the motion to dismiss and granted her clarification motion.

Court’s Analysis

The court agreed that Rule 201 permits judicial notice at any stage of a proceeding. But the rule applies to facts that are not reasonably disputed because they are generally known or can be accurately determined from reliable sources. The court explained that judicial notice is not a vehicle for presenting legal principles. Because the materials listed in Joyner’s earlier motion were rules, legal citations, and dictionary definitions—not appropriate materials for judicial notice—the court upheld the earlier denial while leaving open the possibility of a proper request later.

The court rejected Joyner’s challenge based on the absence of supporting affidavits. Under Federal Rule of Civil Procedure 12(b)(6), a motion to dismiss for failure to state a claim is generally decided from the complaint’s allegations and materials attached to, incorporated into, or integral to the complaint. The court stated that it could not and would not consider supporting affidavits or other outside documents that did not fall within those categories, even if the defendants had submitted them.

Disposition

The court granted in part and denied in part Joyner’s Motion for Clarification. It denied the Proposed Order. The order did not grant or deny the defendants’ pending motion to dismiss. The Clerk was directed to close the docket entries for Joyner’s Motion for Clarification and Proposed Order.