Brown v. Chatham County Voter's Registration

CourtDistrict Court, S.D. Georgia
DecidedMarch 15, 2023
Docket4:22-cv-00235
StatusUnknown

This text of Brown v. Chatham County Voter's Registration (Brown v. Chatham County Voter's Registration) is published on Counsel Stack Legal Research, covering District Court, S.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brown v. Chatham County Voter's Registration, (S.D. Ga. 2023).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF GEORGIA SAVANNAH DIVISION

ROSALIND BROWN, ) ) Plaintiff, ) ) v. ) CV422-235 ) CHATHAM COUNTY VOTER’S ) REGISTRATION OFFICE, et. ) al., ) ) Defendants. )

ORDER AND REPORT AND RECOMMENDATION Pro se plaintiff Rosalind Brown has filed this action asserting that Chatham County Voter’s Registration Office and two of its employees discriminated against her, in violation of the Americans with Disabilities Act. See doc. 1. The Court granted, in part, her request to pursue this case in forma pauperis, doc. 5, and she has complied with the terms imposed. She has also submitted an Amended Complaint. Doc. 6. Since she is entitled to amend her pleading as a matter of course, see Fed. R. Civ. P. 15(a)(1), the Court proceeds to screen her Amended Complaint, see 28 U.S.C. § 1915(e)(2)(B). “Failure to state a claim under § 1915(e)(2)(B)(ii) is governed by the same standard as dismissal for failure to state a claim under [Federal

Rule of Civil Procedure] 12(b)(6).” Wilkerson v. H & S, Inc., 366 F. App'x 49, 51 (11th Cir. 2010) (citing Mitchell v. Farcass, 112 F.3d 1483, 1490

(11th Cir. 1997)). To avoid dismissal, plaintiff’s pleadings must “state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). “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.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). The pleadings

cannot rest merely on an “unadorned, the-defendant-unlawfully-harmed- me accusation,” id. at 678, and the facts offered in support of the claims must rise to a level greater than mere speculation, Twombly, 550 U.S. at

555. Stated otherwise, the complaint must provide a “‘plain statement’ possess[ing] enough heft to ‘sho[w] that the pleader is entitled to relief.’” Id. at 557 (quoting Fed. R. Civ. P. 8(a)(2)).

Brown’s Amended Complaint alleges that she suffers from seizures and lupus. See doc. 6 at 4. She requested an accommodation from the Chatham County Voter’s Registration Office to allow her to attend medical appointments. See id. at 5. Although she does not explicitly allege that her requested accommodation was refused, the Court infers

that it was. See id. Finally, she alleges that she received a right-to-sue letter from the United States Equal Employment Opportunity

Commission on September 28, 2022. Id. To state a claim of discrimination under the ADA, a plaintiff must allege that, at the time of the adverse action, she was (1) disabled, (2)

qualified for the position, and (3) subjected to unlawful discrimination because of her disability. See Mazzeo v. Color Resolutions Intern., LLC, 746 F.3d 1264, 1268 (11th Cir. 2014). A person is “disabled” under the

ADA in three different ways: (1) if she has “a physical or mental impairment that substantially limits one or more . . . major life activities”; (2) if she has a record of such an impairment; or (3) if she is

“regarded as” having such an impairment. 42 U.S.C. § 12102(1). One “major life activity” is working. D’Angelo v. ConAgra Foods, Inc., 422 F.3d 1220, 1226-27 (11th Cir. 2005). A “qualified individual” is someone

with a disability who, “with or without reasonable accommodation, can perform the essential functions of the employment position that such individual holds or desires.” 42 U.S.C. § 12111(8). An employer’s failure to make reasonable accommodation for an otherwise qualified disabled employee constitutes discrimination under the ADA. D’Angelo, 422 F.3d

at 1225-26; see also Anderson v. Embarq/Spirit, 379 F. App’x. 924, 927 (11th Cir. 2010) (“An employer impermissibly discriminates against a

qualified individual when the employer does not reasonably accommodate the individual's disability.” (citing 42 U.S.C. § 12112(b)(5)(A))). Brown’s allegations, taken as true, are sufficient to

allege discrimination. Although Brown has sufficiently alleged that she was discriminated against when her employer failed to accommodate her seizures and

lupus, she has not sufficiently alleged any claims against the individual defendants since the ADA does not provide for individual liability. The ADA provides that “[n]o covered entity shall discriminate against a

qualified individual on the basis of disability in regard to job application procedures, the hiring, advancement, or discharge of employees, employee compensation, job training, and other terms, conditions, and

privileges of employment.” 42 U.S.C. § 12112(a). “The term “covered entity” means “an employer, employment agency, labor organization, or joint labor-management committee.” 42 U.S.C. § 12111(2). This does not allow for individual liability. See Albra v. Advan, Inc., 490 F.3d 826, 830 (11th Cir. 2007) (“… individual liability is precluded for violations of the

’DA's employment discrimination provision . . . .”). Brown’s ADA claims against Defendants Addison and Brown should, therefore, be

DISMISSED. Under the Federal Rules of Civil Procedure, “[t]he plaintiff is responsible for having the summons and complaint served within [ninety

days].” Fed. R. Civ. P. 4(c)(1), (m). The Rules also provide that “[a]ny person who is at least 18 years old and not a party may serve a summons and complaint.” Fed. R. Civ. P. 4(c)(2). Alternatively, a plaintiff

authorized to proceed in forma pauperis is entitled to service by the United States marshal or deputy marshal, “[a]t the plaintiff’s request.” Fed. R. Civ. P. 4(c)(3); see Nagy v. Dwyer, 507 F.3d 161, 164 (2d Cir. 2007)

(“[T]he district court may require plaintiffs proceeding in forma pauperis to affirmatively request that the court appoint the Marshals to serve the summons and complaint on the defendant.”); see also, 4A Adam N.

Steinman, Federal Practice & Procedure Civil § 1090 (4th ed. 2022) (“Service of a summons and complaint by a marshal must be utilized—if requested by the plaintiff—when the plaintiff is proceeding in an action in forma pauperis . . . .”).

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Related

Mitchell v. Farcass
112 F.3d 1483 (Eleventh Circuit, 1997)
Cris D'Angelo v. Conagra Foods, Inc.
422 F.3d 1220 (Eleventh Circuit, 2005)
Betty K Agencies, Ltd. v. M/V Monada
432 F.3d 1333 (Eleventh Circuit, 2005)
Adem A. Albra v. Advan, Inc.
490 F.3d 826 (Eleventh Circuit, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Nagy v. Dwyer
507 F.3d 161 (Second Circuit, 2007)
Vincent Vidal Mitchell v. United States
612 F. App'x 542 (Eleventh Circuit, 2015)
Anthony Mazzeo v. Color Resolutions Int'l, LLC
746 F.3d 1264 (Eleventh Circuit, 2014)
Carol Wilkerson v. H&S, Inc.
366 F. App'x 49 (Eleventh Circuit, 2010)
Maurice Symonette v. V.A. Leasing Corporation
648 F. App'x 787 (Eleventh Circuit, 2016)

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Brown v. Chatham County Voter's Registration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brown-v-chatham-county-voters-registration-gasd-2023.