Ahmad v. Day

Background

Mahfooz Ahmad, proceeding without a lawyer, sued over alleged employment discrimination and mistreatment and the alleged theft of his intellectual property. He asked for permission under Federal Rule of Civil Procedure 15 to file a proposed second amended complaint adding or reasserting claims against iCIMS Inc.; Colin Day and Courtney Dutter; Beacon Hill Staffing Group; naviHealth Inc.; Clay Richards; Vista Equity Partners; Susquehanna Growth Equity; and Comcast Corporation.

The proposed complaint alleged, among other things, that iCIMS treated Ahmad unfairly at work, interfered with his Friday prayers, required excessive unpaid work, learned about his Jobtrail business idea, and then terminated him. It also alleged that Beacon and naviHealth made promises about full-time employment and improperly reported his wages, and that various defendants were involved in taking or using his intellectual property.

Rulings on the Proposed Defendants

The court would not permit Vista to be added or retained because the proposed complaint identified no specific conduct by Vista connected to Ahmad’s alleged injuries. Vista’s investment in iCIMS, occurring about two months after Ahmad’s termination, did not establish the required connection for personal jurisdiction.

The court denied leave to amend as to Beacon, naviHealth, and Clay Richards. It found that the proposed intellectual-property allegations did not show a connection between those defendants and any alleged conduct by iCIMS. The employment allegations against Beacon and naviHealth were also too vague to establish a viable fraud, contract, wage-reporting, or fiduciary-duty claim. The allegations against Richards consisted only of a vague and conclusory conspiracy assertion.

The court also denied permission to add Comcast and Susquehanna. The allegations against Comcast concerned its involvement with DreamIt Ventures and an assertion that iCIMS acted on Comcast’s orders, but they did not show that Comcast caused Ahmad’s injury. The allegations against Susquehanna were conclusory and did not identify specific conduct by that entity. The court stated that Ahmad had not shown the causal connection needed for standing or facts establishing personal jurisdiction over either proposed defendant.

Rulings on the iCIMS Defendants

The court rejected the argument that Ahmad was barred from seeking amendment as to iCIMS, Day, and Dutter. It also found that the proposed complaint was sufficiently understandable under Rule 8, even though some allegations were vague or conclusory. Because the iCIMS defendants’ arguments about the merits and possible time limits were cursory or relied on material outside the pleadings, the court did not deny amendment on futility grounds as to them. The court noted that those defendants could raise such arguments in a later motion.

Federal Arbitration Act Notice

Ahmad filed documents challenging the constitutionality of the Federal Arbitration Act. The court made no ruling on that challenge because the case did not present a current claim involving the Act. An earlier request by iCIMS to compel arbitration had been denied.

Disposition

Magistrate Judge Gabriel W. Gorenstein granted in part and denied in part Ahmad’s motion for leave to amend. Ahmad may file the proposed amended complaint only after deleting Beacon Hill Staffing Group, naviHealth Inc., Vista Equity Partners, Clay Richards, Susquehanna Growth Equity, and Comcast Corporation from the caption and defendant list. The permitted defendants are iCIMS Inc., Colin Day, and Courtney Dutter. The amended complaint had to be filed by January 6, 2023.