Buchanan v. Doris Duke Foundation - Shangri-La Museum of Islamic Art

CourtDistrict Court, D. Hawaii
DecidedSeptember 11, 2024
Docket1:24-cv-00383
StatusUnknown

This text of Buchanan v. Doris Duke Foundation - Shangri-La Museum of Islamic Art (Buchanan v. Doris Duke Foundation - Shangri-La Museum of Islamic Art) is published on Counsel Stack Legal Research, covering District Court, D. Hawaii primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Buchanan v. Doris Duke Foundation - Shangri-La Museum of Islamic Art, (D. Haw. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF HAWAI‘I

ROSE A. BUCHANAN, Case No. 24-cv-00383-DKW-WRP

Plaintiff, ORDER (1) GRANTING APPLICATION TO PROCEED IN vs. DISTRICT COURT WITHOUT PREPAYING FEES OR COSTS; DORIS DUKE FOUNDATION – (2) DISMISSING COMPLAINT SHANGRI-LA MUSEUM OF ISLAMIC WITH LEAVE TO AMEND; AND ART, (3) DENYING WITHOUT PREJUDICE REQUEST FOR Defendant. APPOINTMENT OF COUNSEL1

On September 9, 2024, Plaintiff Rose Buchanan, proceeding pro se, filed a Complaint against Defendant Doris Duke Foundation – Shangri-La Museum of Islamic Art (“Foundation”), alleging employment discrimination under Title VII of the Civil Rights Act of 1964. Dkt. No. 1. In addition, Buchanan also filed an application to proceed in forma pauperis, Dkt. No. 3, and a motion for appointment of counsel, Dkt. No. 6. I. IFP Application Pursuant to 28 U.S.C. § 1915(a)(1), federal courts may authorize the commencement of suit without prepayment of fees or securities by a person who

1The Court finds these matters suitable for disposition without a hearing pursuant to Local Rule 7.l(d). submits an affidavit which demonstrates that she lacks the ability to pay. Though an IFP applicant need not demonstrate absolute destitution, Adkins v. E.I. DuPont

de Nemours & Co., 335 U.S. 331, 339 (1948), she must “allege poverty with some particularity, definiteness, and certainty.” Escobedo v. Applebees, 787 F.3d 1226, 1234 (9th Cir. 2015) (quotation marks and citations omitted). The affidavit is

sufficient where it alleges that the applicant “cannot pay the court costs and still afford the necessities of life.” Id. (citing Adkins, 335 U.S. at 339); see 28 U.S.C. § 1915(a)(1). Here, Buchanan has made the requisite showing under Section 1915(a). In

her IFP Application, Buchanan asserts that she is currently unemployed, and her only source of income is $540 per month in food stamps.2 Dkt. No. 3 at 1. In addition, although Buchanan has $2,900 in cash or in a checking or savings

account and no debt, financial obligations, or dependents, she also has no items or assets of value, and her monthly expenses total $2,045.3 Id. at 2. Accordingly, in light of these figures, the Court finds that Buchanan lacks sufficient income to pay or assets to provide security for the filing fee while still affording the necessities of

2This income falls below the poverty threshold identified by the Department of Health and Human Services (“HHS”) 2024 Guidelines for Hawaiʻi. See HHS Poverty Guidelines, available at: https://aspe.hhs.gov/topics/poverty-economic-mobility/poverty-guidelines. 3Although Buchanan states her monthly expenses total $2,050, her listed expenses amount to $2,045 including: $1,310 for rent, $80 for the bus, $55 for her cellphone, and $600 for food. See Dkt. No. 3 at 2. life. See Escobedo, 787 F.3d at 1234–36. Her IFP Application, Dkt. No. 3, is therefore GRANTED.

II. Screening When a plaintiff files an action in forma pauperis pursuant to 28 U.S.C. § 1915(a), the Court subjects it to mandatory screening and may order the

dismissal of any claim it determines “is frivolous or malicious; fails to state a claim upon which relief may be granted; or seeks monetary relief from a defendant who is immune from such relief.” 28 U.S.C. § 1915(e)(2)(B). Though the Court must liberally construe a pro se complaint, Eldridge v. Block, 832 F.2d 1132, 1137 (9th

Cir. 1987), it cannot act as counsel for a pro se litigant, including by providing the essential elements of a claim. Pliler v. Ford, 542 U.S. 225, 231 (2004); Ivey v. Bd. of Regents of Univ. of Alaska, 673 F.2d 266, 268 (9th Cir. 1982). Rather, the

litigant’s “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) (quotation marks and citations omitted). Here, Buchanan’s Complaint does not provide sufficient factual detail to

plausibly state a claim for relief. Title VII of the Civil Rights Act of 1964 prohibits refusing to hire any individual on the basis of race, color, religion, sex, or national origin. See 42 U.S.C. § 2000e-2(a)(1). Buchanan, however, asserts only

that the Foundation “claimed that employment was contingent upon background + references that passed but still backed out off [sic] offer.” Dkt. No. 1 at 3. Although Buchanan questions whether such decision was based on her religion,

sex, or national origin, she provides no factual detail that would support those inferences. See id. In fact, Buchanan specifically states that the Foundation “did not provide any reason” when it informed her that it was no longer moving forward

with her employment. Id. As such, because Buchanan has failed to provide sufficient factual information to state even the most basic element of a Title VII claim—membership in a protected class—the Court cannot find that she has plausibly shown that she is entitled to relief. See Coghlan v. Am. Seafoods Co.

LLC., 413 F.3d 1090, 1094 (9th Cir. 2005) (outlining the framework for evaluating disparate treatment claims). The Complaint, Dkt. No. 1, must therefore be DISMISSED, albeit with leave to amend, as detailed below.

III. Appointment of Counsel Under 42 U.S.C. § 2000e-5(f)(1), a plaintiff bringing employment discrimination claims under Title VII may seek the appointment of counsel. In evaluating such requests, the Court considers three factors: “(1) the plaintiff’s

financial resources; (2) the efforts made by the plaintiff to secure counsel on his or her own; and (3) the merit of the plaintiff’s claim.” Id. at 416–17 (quotation marks and citation omitted). Although the ultimate decision is “left to the sound

discretion of the district court,” Johnson v. United States Treasury Dep’t, 27 F.3d 415, 416 (9th Cir. 1994), the plaintiff has the burden of persuasion as to all three factors, and an unfavorable finding as to any one factor may be fatal to the request,

see Williams v. 24 Hour Fitness USA, Inc., 2014 WL 7404604, at *2 (D. Haw. Dec. 30, 2014). Here, as discussed above, the Court finds that the Complaint lacks sufficient

factual detail to state a meritorious claim for relief. See supra 3–4. Consequently, Buchanan’s request for the appointment of counsel, Dkt. No. 6, is DENIED WITHOUT PREJUDICE. IV. Leave to Amend

Although the Complaint, as written, fails to state a plausible claim for relief, it may nevertheless be possible for Buchanan to allege sufficient factual detail to do so.

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Related

Adkins v. E. I. DuPont De Nemours & Co.
335 U.S. 331 (Supreme Court, 1948)
Pliler v. Ford
542 U.S. 225 (Supreme Court, 2004)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Ivey v. Board of Regents of University of Alaska
673 F.2d 266 (Second Circuit, 1982)
Edward G. Eldridge v. Sherman Block
832 F.2d 1132 (Ninth Circuit, 1987)
James W. Coghlan v. American Seafoods Company LLC
413 F.3d 1090 (Ninth Circuit, 2005)
Maria Escobedo v. Apple American Group
787 F.3d 1226 (Ninth Circuit, 2015)

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