Bissett v. ALS GROUP USA, CORP

CourtDistrict Court, D. Nevada
DecidedDecember 4, 2020
Docket3:20-cv-00036
StatusUnknown

This text of Bissett v. ALS GROUP USA, CORP (Bissett v. ALS GROUP USA, CORP) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bissett v. ALS GROUP USA, CORP, (D. Nev. 2020).

Opinion

1 2 3 4 5 6 UNITED STATES DISTRICT COURT

7 DISTRICT OF NEVADA

8 * * * 9 LANDON BISSETT, Case No. 3:20-cv-00036-LRH-CLB Plaintiff, 10 v. ORDER

11 ALS USA, INC., Defendant. 12 13 14 Before the Court is Defendant ALS USA, INC.’s (“ALS”) motion to dismiss (ECF No. 15 12) Plaintiff Landon Bissett’s (“Bissett”) first amended complaint (ECF No. 8); specifically, the 16 second cause of action for retaliation. Bissett opposes the motion (ECF No. 14), and ALS replied 17 (ECF No. 15). For the reasons contained in this Order, the Court will grant the motion to dismiss 18 the second cause of action, but Bissett is granted leave to file an amended complaint. 19 I. BACKGROUND 20 Bissett is a resident of northern Nevada who worked for ALS from November 11, 2017, to 21 November 19, 2018. ECF No. 12-1. ALS “is a professional organization that provides analytical 22 testing services to a wide variety around the world.” During his employment with ALS, Bissett 23 worked as a Fire Tech I. According to Bissett’s Nevada Equal Rights Commission (“NERC”) 24 Charge, he was subject to sexual harassment on a regular basis, primarily from his co-worker 25 Isidoro Gutierrez (“Gutierrez”). ECF No. 12-1. 26 About a month after Bissett began working for ALS, Gutierrez apparently began offering 27 “…[Bissett] money in exchange for sexual relations with [Bissett’s] girlfriend, touch[ed] [Bissett] 1 of these interactions, and even engaged in similar inappropriate behavior. Id. Most troubling, 2 according to Bissett, Gutierrez showed him a video of child pornography which Bissett claims 3 Gutierrez produced. Id. In July of 2018, Bissett informed his supervisor, Jeff Nielson (“Nielson”), 4 that he no longer wished to be the subject of sexual harassment. Id. 5 Eventually, Bissett was terminated on November 19, 2018, for, according to ALS, chronic 6 tardiness and absenteeism. The lead up to his firing spanned several months. On February 21, 7 2018, Bissett received his first warning regarding five absences. ECF No. 12-2. On September 6, 8 2018, Bissett received his second warning regarding an absence on September 1, 2018. ECF No. 9 12-3. On September 21, 2018, Bissett received his third and final warning because he continued 10 to call in sick. ECF No. 12-4. On November 19, 2018, Bissett was terminated after he failed to 11 appear for a shift on November 16, 2018. ECF No. 12-6. Bissett claims his tardiness and 12 absenteeism was a result of the sexual hostile work environment, and his termination constituted 13 retaliation. ECF No. 1. 14 This action was filed on January 17, 2020. Id. Bissett alleges a sexual hostile work 15 environment and retaliation in violation of 42 U.S.C. 2000e, et seq. Id. The retaliation cause of 16 action is the subject of ALS’ motion to dismiss now pending before the Court. 17 II. LEGAL STANDARD 18 A party may seek the dismissal of a complaint under Federal Rule of Civil Procedure 19 12(b)(6) for failure to state a legally cognizable cause of action. See Fed. R. Civ. P. 12(b)(6) 20 (stating that a party may file a motion to dismiss for “failure to state a claim upon which relief can 21 be granted[.]”). To survive a motion to dismiss for failure to state a claim, a complaint must satisfy 22 the notice pleading standard of Federal Rule 8(a)(2). See Mendiondo v. Centinela Hosp. Med. Ctr., 23 521 F.3d 1097, 1103 (9th Cir. 2008). Under Rule 8(a)(2), a complaint must contain “a short and 24 plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). 25 Rule 8(a)(2) does not require detailed factual allegations; however, a pleading that offers only 26 “‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action’” is 27 insufficient and fails to meet this broad pleading standard. Ashcroft v. Iqbal, 556 U.S. 662, 678 1 To sufficiently allege a claim under Rule 8(a)(2), viewed within the context of a 2 Rule 12(b)(6) motion to dismiss, a complaint must “contain sufficient factual matter, accepted as 3 true, to ‘state a claim to relief that is plausible on its face.’” Id. (quoting Twombly, 550 U.S. at 4 570). A claim has facial plausibility when the pleaded factual content allows the court to draw the 5 reasonable inference, based on the court’s judicial experience and common sense, that the 6 defendant is liable for the alleged misconduct. See id. at 678-679 (stating that “[t]he plausibility 7 standard is not akin to a probability requirement, but it asks for more than a sheer possibility that 8 a defendant has acted unlawfully. Where a complaint pleads facts that are merely consistent with 9 a defendant’s liability, it stops short of the line between possibility and plausibility of entitlement 10 to relief.”) (internal quotation marks and citations omitted). Further, in reviewing a motion to 11 dismiss, the court accepts the factual allegations in the complaint as true. Id. However, bare 12 assertions in a complaint amounting “to nothing more than a formulaic recitation of the elements 13 of a . . . claim . . . are not entitled to an assumption of truth.” Moss v. U.S. Secret Serv., 572 F.3d 14 962, 969 (9th Cir. 2009) (quoting Iqbal, 556 U.S. at 698) (internal quotation marks omitted). The 15 court discounts these allegations because “they do nothing more than state a legal conclusion— 16 even if that conclusion is cast in the form of a factual allegation.” Id. “In sum, for a complaint to 17 survive a motion to dismiss, the non-conclusory ‘factual content,’ and reasonable inferences from 18 that content, must be plausibly suggestive of a claim entitling the plaintiff to relief.” Id. 19 III. DISCUSSION 20 In their motion to dismiss, ALS requests dismissal of Bissett’s second cause of action: 21 retaliation. 22 Section 2000e–3(a) makes it unlawful for an employer “to discriminate against any of [is] 23 employees … because [the employee] has opposed any practice made an unlawful employment 24 practice” by Title VII. 42 U.S.C. § 2000e–3(a). When claiming retaliation, a plaintiff must prove 25 “(1) that [they were] engaging in protected activity/opposition, (2) that [they] suffered an adverse 26 employment action, and (3) that there was a casual link between [their] activity and the 27 employment decision.” Folkerson v. Circus Circus Enterprises, Inc., 107 F.3d 754, 756 (9th Cir. 1 but-for causation, e.g., merely showing that retaliation was a motivating factor for the adverse 2 employment action is insufficient. See University of Texas Southwestern Medical Center v. Nassar, 3 570 U.S. 338, 361 (2013) (finding that Congress intended to confine motivating-factor causation 4 to status-based discrimination—not retaliation claims). 5 ALS argues Bissett’s retaliation claim fails to establish the final but-for requirement. ECF 6 No. 12, at 5–6. Essentially, ALS contends that the primary reason for Bissett’s termination— 7 absenteeism and tardiness—supplants any theory of retaliation arising from Bissett’s complaints 8 of sexual harassment. Id. Bissett responds by generally relying on three cases which purportedly 9 contradict ALS. See Harris v.

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Bissett v. ALS GROUP USA, CORP, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bissett-v-als-group-usa-corp-nvd-2020.