Black v. Ohio Industrial Commission

District Court, S.D. Ohio·Decided September 22, 2022·No. 2:21-cv-02987·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

Rachel Black, Case No: 2:21-cv-2987 Plaintiff, Judge Graham v. Magistrate Judge Jolson State of Ohio Industrial Commission, et al., Defendants. Opinion and Order Plaintiff Rachel Black, proceeding pro se, brings this action against her employer, the State of Ohio Industrial Commission, and Chairman James Hughes and Executive Director Timothy Adams. Ms. Black, who is Hispanic, asserts claims under Title VII of the Civil Rights Act of 1964 for national origin discrimination and gender discrimination. She also asserts a claim under the Equal Pay Act. This matter is before the Court on defendants’ motion to partially dismiss the claims. Plaintiff did not respond to the motion. Defendants argue that to the extent the complaint can be construed to assert a hostile work environment claim, any such claim fails because plaintiff did not include allegations of a hostile work environment in the Charge she filed with the Equal Employment Opportunity Commission. Defendants additionally argue that the Equal Pay Act claim fails because it is time-barred and because payroll records show that plaintiff earned more than her male counterpart. I. The Second Amended Complaint alleges that Ms. Black began her employment with the Ohio Industrial Commission as an attorney in 1993. After serving as a District Hearing Officer for many years, she was appointed to Chief Legal Counsel in 2013. On July 1, 2019, Governor Michael DeWine appointed defendant Hughes to the position of Chairman of the Commission. According to plaintiff, Hughes attempted to terminate her employment on July 25, 2019 without cause and claimed that he wanted to go in a “new direction.” Plaintiff immediately asserted her “fall-back rights” to return to her previous position as a hearing officer. Hughes claimed that plaintiff did not have fall-back rights. After reporting the matter to Human Resources, plaintiff received a hearing officer position on July 29, 2019. Plaintiff alleges that the pay and other terms and conditions of her employment as a hearing officer were unfavorable in comparison to her employment as Chief Legal Counsel. Plaintiff filed a charge with the Equal Employment Opportunity Commission on July 21, 2020 and received a Right to Sue letter on March 2, 2021. Plaintiff filed her complaint in this case on June 1, 2021. She has twice been granted leave to amend her complaint. Counts I and II of the Second Amended Complaint assert claims of national origin discrimination under state law (Count I) and Title VII, 42 U.S.C. § 2000e-2(a) (Count II). Counts III and IV assert claims of gender discrimination under Title VII (Count III) and state law (Count IV). The complaint alleges that defendants discriminated against plaintiff by terminating her position as Chief Legal Counsel, by initially refusing to honor her fall back rights, and by treating her less favorably than non-Hispanic, male employees in the terms and conditions of employment. Count V asserts a violation of the Equal Pay Act, 29 U.S.C § 206(d)(1). The complaint alleges that plaintiff was paid less and received fewer benefits than her white male counterparts. II. When considering a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), a court must determine whether the complaint “contain[s] 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) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007)). A court should construe the complaint in the light most favorable to the plaintiff and accept all well-pleaded material allegations in the complaint as true. Iqbal, 556 U.S. at 679; Erickson v. Pardus, 551 U.S. 89, 93-94 (2007); Twombly, 550 U.S. at 555-56. III. A. Defendants move to dismiss any claims under Counts II and III which could be construed as asserting the existence of a hostile work environment. It is unclear from the face of the complaint whether plaintiff intended to assert a hostile work environment claim, and plaintiff has not responded to defendants’ motion to dismiss. The complaint contains allegations relating to Jacob Bell, a non-defendant who worked for the Ohio Industrial Commission in some unspecified capacity. In 2015, Mr. Bell allegedly screamed at plaintiff behind a locked door for fifteen minutes. Plaintiff reported the incident to a supervisor and said she felt intimidated, but no disciplinary action was taken against Mr. Bell. At about the same time, Mr. Bell allegedly used racial derogatory terms in referring to plaintiff’s Puerto Rican descent. The complaint further alleges that Mr. Bell’s employment was later terminated following an investigation into reports that he had harassed and created a hostile work environment for female employees.1 The basis for defendants’ motion to dismiss any potential hostile work environment claim is that plaintiff did not exhaust her administrative remedies. Defendants argue that plaintiff’s EEOC Charge did not contain any allegations relating to a hostile work environment. “[A]n employee alleging employment discrimination in violation of [Title VII] must first file an administrative charge with the EEOC within a certain time after the alleged wrongful act or acts.” Younis v. Pinnacle Airlines, Inc., 610 F.3d 359, 361 (6th Cir. 2010) (citing 42 U.S.C. § 2000e–5(e)(1)); see also Scott v. Eastman Chem. Co., 275 Fed. App’x 466, 470 (6th Cir. 2008) (“As a prerequisite to bringing suit under Title VII, a claimant must exhaust his or her administrative remedies.”). The charge must be “sufficiently precise to identify the parties, and to describe generally the action or practices complained of.” 29 C.F.R. § 1601.12(b). “This rule serves the dual purpose of giving the employer information concerning the conduct about which the employee complains, as well as affording the EEOC and the employer an opportunity to settle the dispute through conference, conciliation, and persuasion.” Younis, 610 F.3d at 361. The exhaustion requirement “is not meant to be overly rigid, nor should it result in the restriction of subsequent complaints based on procedural technicalities or the failure of the charges to contain the exact wording which might be required in a judicial pleading.” Randolph v. Ohio Dep't of Youth Servs., 453 F.3d 724, 732 (6th Cir. 2006) (internal quotation marks omitted). An EEOC charge should be construed to encompass all claims “‘reasonably expected to grow out of the charge of discrimination.” Haithcock v. Frank, 958 F.2d 671, 675 (6th Cir. 1992)); see also Younis, 610 F.3d at 362 (“[C]ourts may also consider claims that are reasonably related to or grow out of the factual allegations in the EEOC charge.”).

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