ANDERSON v. WALMART DISTRIBUTION CENTER

CourtDistrict Court, S.D. Indiana
DecidedJune 6, 2024
Docket1:23-cv-01071
StatusUnknown

This text of ANDERSON v. WALMART DISTRIBUTION CENTER (ANDERSON v. WALMART DISTRIBUTION CENTER) is published on Counsel Stack Legal Research, covering District Court, S.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
ANDERSON v. WALMART DISTRIBUTION CENTER, (S.D. Ind. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

DENEICE ANDERSON, ) ) Plaintiff, ) ) v. ) No. 1:23-cv-01071-SEB-MJD ) WAL-MART ASSOCIATES, INC., ) WALMART INC., ) WAL-MART STORES EAST, LP, ) ) Defendants. )

ORDER GRANTING DEFENDANTS' MOTION TO DISMISS This matter is before the Court on Defendants Wal-Mart Associates, Inc., Walmart Inc., and Wal-Mart Stores East, LP's (collectively "Defendants") Motion to Dismiss pro se Plaintiff Deneice Anderson's ("Ms. Anderson") Complaint. For the reasons explained be- low, Defendants' motion is GRANTED. STANDARD OF REVIEW Federal Rule of Civil Procedure 8(a) requires a federal pleading to contain "a short and plain statement showing that the pleader is entitled to relief." To survive a motion to dismiss, pursuant to Rule 12(b)(6), the "complaint must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face." Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (internal quotation omitted). "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. Put differently, it is not enough for a plaintiff to say that she has been illegally harmed. She must also state enough facts in her complaint for the Court to infer the ways in which the named Defendants could be held liable for the harm alleged.

Thus, "a plaintiff must do better than putting a few words on paper that, in the hands of an imaginative reader, might suggest that something has happened to her that might be redressed by the law." Swanson v. Citibank, N.A., 614 F.3d 400, 403 (7th Cir. 2010) (em- phasis in original). Pro se complaints, such as that filed by Ms. Anderson, are construed liberally and held "to a less stringent standard than formal pleadings drafted by lawyers." Perez v. Fenoglio, 792 F.3d 768, 776 (7th Cir. 2015) (internal quotation omitted).

When evaluating the sufficiency of a complaint's factual allegations, courts may consider "documents attached to a motion to dismiss . . . if they are referred to in the plain- tiff's complaint and are central to h[er] claim." Wright v. Associated Ins. Cos., 29 F.3d 1244, 1248 (7th Cir. 1994). Defendants here have attached to their Motion to Dismiss Ms. An- derson's Charge of Discrimination, which we properly consider because Ms. Anderson re-

fers to it in her Complaint and it is central to her claims. FACTUAL BACKGROUND For purposes of this Rule 12(b)(6) motion, "we assume all well-pleaded facts are true and view those facts in the light most favorable to the plaintiff." Menominee Indian Tribe of Wisconsin v. Thompson, 161 F.3d 449, 456 (7th Cir. 1998).

Ms. Anderson brought this action against Walmart, her former employer, alleging that it unlawfully discriminated against her on the basis of disability, in violation of the Americans with Disabilities Act of 1990 (the "ADA"), 42 U.S.C. § 12112 et seq. Ms. Anderson avers that she suffers a qualifying disability, though she has not specified what her disability is.

Ms. Anderson alleges that, after returning from bereavement leave in September 2019, her employer temporarily assigned her to work in a different department. She appar- ently requested that she return to her usual department "to adjust to the flow of working again," which request was denied by her supervisor. Charge of Discrimination 2, dkt. 14- 1. Ms. Anderson attempted to adjust to the fast-paced environment of this new department, but she experienced an unspecified "medical event" for which she received three hours of

medical treatment. Ms. Anderson returned to work the next day, and shortly thereafter, the human resources department circulated an email to remind management that employees should not be assigned to work outside their usual departments. According to Ms. Ander- son, she was issued a "step 3 reprimand" soon thereafter, despite having no prior discipli- nary record. Ms. Anderson avers that she reported this disciplinary incident to the President

of the company. Later that week, the company's Assistant President visited Ms. Anderson's workplace, retrained management, and removed the step 3 reprimand from her work file. In November 2020, Ms. Anderson requested and was granted leave "connected to the difficulties with childcare that [COVID-19] caused." Id. In May 2021, Ms. Anderson received a telephone call from her employer, during which her employer allegedly threat-

ened to terminate her employment if she did not promptly return to work. When Ms. An- derson returned to work in June 2021, she "began receiving regular write-ups for not meet- ing performance standards," and "was consistently harassed . . . by Human Resources." Id. at 3. Upon her return from a seven-day medical leave on December 23, 2021, Ms. An- derson was terminated.

On September 14, 2022, Ms. Anderson filed a Charge of Discrimination with the Equal Employment Opportunity Commission (the "EEOC"), alleging that she had been discriminated against in violation of the ADA. On March 27, 2023, she received a Notice of Right to Sue Letter from the EEOC, which letter provided her through June 25, 2023, to file a lawsuit (though the letter was not attached to the Complaint). On June 20, 2023, Ms. Anderson filed the instant Complaint, averring that Walmart

unlawfully discriminated against her by imposing unequal terms and conditions on her em- ployment; failing to accommodate her disability; and terminating her employment. De- fendants have moved to dismiss the Complaint, which motion awaits a ruling. DISCUSSION In moving to dismiss, Defendants contend that Ms. Anderson's claims are time-

barred and that Ms. Anderson has otherwise failed to allege facts that plausibly suggest her termination was connected to any alleged disability. We address both arguments below. I. TIME-BARRED CLAIMS A charge of discrimination under the ADA must be filed with the Equal Employment and Opportunity Commission within 300 days of the alleged violation. Sharp v. United

Airlines Inc., 236 F.3d 368, 372 (7th Cir. 2001). This 300-day clock "begins to run when the defendant has taken the action that injures the plaintiff and when the plaintiff knows she has been injured." Id. An untimely claim is barred and cannot proceed. Muckenfuss v. Tyson Fresh Meats, Inc., 581 F. Supp. 3d 1114, 1119 (N.D. Ind. 2022) (citing Conley v. Vill. of Bedford Park, 215 F.3d 703, 710 (7th Cir. 2000)).

Here, Ms. Anderson filed her EEOC Charge on September 14, 2022; therefore, her claims that accrued prior to November 18, 2021, are time-barred. Ms. Anderson alleges that, after returning from bereavement leave in September 2019, she was temporarily placed in a different department, which caused the onset of a medical emergency. Ms. An- derson also alleges that she took COVID-19-related leave from November 2020 through June 2021, during which leave her employer allegedly phoned her and threatened termina-

tion if she failed to return to work. By Ms.

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