Allen v. Amazon.com, Inc.

CourtDistrict Court, E.D. Missouri
DecidedNovember 1, 2021
Docket4:21-cv-01275
StatusUnknown

This text of Allen v. Amazon.com, Inc. (Allen v. Amazon.com, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Allen v. Amazon.com, Inc., (E.D. Mo. 2021).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

MICHELLE N. ALLEN, ) ) Plaintiff, ) ) v. ) No. 4:21-CV-1275-AGF ) AMAZON.COM, INC., ) ) Defendant. )

MEMORANDUM AND ORDER This matter comes before the Court on review of plaintiff’s motion for leave to commence this employment discrimination action without payment of the required filing fee. ECF No. 2. Having reviewed the application and financial information provided, the Court has determined to grant the motion. See 28 U.S.C. § 1915. Additionally, for the reasons discussed below, the Court will direct plaintiff to file an amended complaint. Legal Standard on Initial Review Under 28 U.S.C. § 1915(e)(2), the Court is required to dismiss a complaint filed in forma pauperis if it is frivolous, malicious, or fails to state a claim upon which relief can be granted. To state a claim under 42 U.S.C. § 1983, a plaintiff must demonstrate a plausible claim for relief, which is more than a “mere possibility of misconduct.” Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. at 678. Determining whether a complaint states a plausible claim for relief is a context-specific task that requires the reviewing court to draw upon judicial experience and common sense. Id. at 679. The court must “accept as true the facts alleged, but not legal conclusions or threadbare recitals of the elements of a cause of action, supported by mere conclusory statements.” Barton v. Taber, 820 F.3d 958, 964 (8th Cir. 2016). See also Brown v. Green Tree Servicing LLC, 820 F.3d 371, 372- 73 (8th Cir. 2016) (stating that court must accept factual allegations in complaint as true, but is not required to “accept as true any legal conclusion couched as a factual allegation”).

When reviewing a self-represented plaintiff’s complaint under § 1915(e)(2), the Court must give it the benefit of a liberal construction. Haines v. Kerner, 404 U.S. 519, 520 (1972). A “liberal construction” means that if the essence of an allegation is discernible, the district court should construe the plaintiff’s complaint in a way that permits his or her claim to be considered within the proper legal framework. Solomon v. Petray, 795 F.3d 777, 787 (8th Cir. 2015). However, even self-represented complaints are required to allege facts which, if true, state a claim for relief as a matter of law. Martin v. Aubuchon, 623 F.2d 1282, 1286 (8th Cir. 1980). See also Stone v. Harry, 364 F.3d 912, 914-15 (8th Cir. 2004) (stating that federal courts are not required to “assume facts that are not alleged, just because an additional factual allegation would have formed a stronger complaint”). In addition, affording a self-represented complaint the benefit of a liberal construction

does not mean that procedural rules in ordinary civil litigation must be interpreted so as to excuse mistakes by those who proceed without counsel. See McNeil v. United States, 508 U.S. 106, 113 (1993). The Complaint Plaintiff initiated this action on October 25, 2021 by filing an employment discrimination complaint against defendant Amazon.com, Inc. ECF No. 1. The complaint is on a Court-provided form, as required. Plaintiff placed check marks indicating she brings this lawsuit pursuant to Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. §§ 2000e, et seq., and the Age Discrimination in Employment Act of 1967, as amended, 29 U.S.C. §§ 621, et seq., for termination of her employment, retaliation, and harassment. She also placed check marks indicating she believes she was discriminated against on the basis of race, color, gender, and age. Plaintiff states she seeks to be compensated for her lost wages. Plaintiff, however, left blank the space provided for her to state the facts of her claim and describe the conduct she alleges is discriminatory.

Attached to her complaint is a copy of the administrative charge she filed with the Missouri Commission on Human Rights (MCHR) and right-to-sue letter she received from the Equal Employment Opportunity Commission (EEOC), dated July 23, 2021. ECF Nos. 1-3, 1-4. It therefore appears plaintiff has timely brought this action.1 Discussion The complaint is subject to dismissal because plaintiff has not alleged facts in support of the claims she wishes to bring before this Court. Simply checking boxes is insufficient. Even self- represented plaintiffs are required to allege facts in support of their claims, and courts will not assume facts that are not alleged. See Stone, 364 F.3d at 914-15. In consideration of plaintiff’s self-represented status, the Court will give her the

opportunity to file an amended complaint to clearly set forth the claims she wishes to bring before this Court and the factual allegations in support of those claims. Plaintiff is advised that the claims she brings before this Court must be like or reasonably related to the claims outlined in her administrative charge or they will be subject to dismissal for failure to exhaust administrative remedies. See, e.g., Duncan v. Delta Consolidated Indus., Inc., 371 F.3d 1020, 1024 (8th Cir. 2004).

1 Plaintiff presumably received her right-to-sue letter from the EEOC within three to five days of July 23, 2021, the date it was issued. See, e.g., Baldwin County Welcome Center v. Brown, 466 U.S. 147, 148 n. 1 (1984) (noting a rebuttable presumption that a claimant receives correspondence from an agency three days after it was mailed); but see, Barnes v. Riverside Seat Co., 46 Fed. Appx. 385, 285 (8th Cir. 2002) (citing with approval application of five- day presumption); Walton v. U.S. Dept. of Agriculture, 2007 WL 1246845 at *8 (E.D. Mo. Apr. 30, 2007) (same). Plaintiff filed this action on October 25, 2021, which was 95 days after her right-to-sue letter was issued. The amended complaint will replace the original complaint. E.g., In re Wireless Telephone Federal Cost Recovery Fees Litigation, 396 F.3d 922, 928 (8th Cir. 2005). Plaintiff must submit the amended complaint on a Court-provided form, and she must comply with the Federal Rules of Civil Procedure, including Rules 8 and 10. Rule 8 requires plaintiff to set forth

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Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Baldwin County Welcome Center v. Brown
466 U.S. 147 (Supreme Court, 1984)
McNeil v. United States
508 U.S. 106 (Supreme Court, 1993)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Anderson v. Durham D & M, L.L.C.
606 F.3d 513 (Eighth Circuit, 2010)
James Solomon v. Deputy U.S. Marshal Thomas
795 F.3d 777 (Eighth Circuit, 2015)
Pointer v. Missouri Department of Corrections
46 F. App'x 385 (Eighth Circuit, 2002)
Raymond L. Brown v. Green Tree Servicing LLC
820 F.3d 371 (Eighth Circuit, 2016)
Barton Ex Rel. Estate of Barton v. Taber
820 F.3d 958 (Eighth Circuit, 2016)
Patric Patterson v. Kennie Bolden
902 F.3d 845 (Eighth Circuit, 2018)
Martin v. Aubuchon
623 F.2d 1282 (Eighth Circuit, 1980)

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Bluebook (online)
Allen v. Amazon.com, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/allen-v-amazoncom-inc-moed-2021.