Daniels v. Texas Workforce Commission

CourtDistrict Court, N.D. Texas
DecidedDecember 10, 2024
Docket4:24-cv-00559
StatusUnknown

This text of Daniels v. Texas Workforce Commission (Daniels v. Texas Workforce Commission) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Daniels v. Texas Workforce Commission, (N.D. Tex. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS FORT WORTH DIVISION

BRIAUNNA DANIELS, § § Plaintiff, § § v. § Civil Action No. 4:24-cv-00559-O-BP § TEXAS WORKFORCE § COMMISSION, et al., § § Defendants. §

FINDINGS, CONCLUSIONS, AND RECOMMENDATION OF THE UNITED STATES MAGISTRATE JUDGE

Before the Court are the Motion to Dismiss, Brief in Support, and Appendix filed in Support, that Defendant AmeriCredit Financial Services Inc. dba GM Financial (“GMF”) filed on August 23, 2021 (ECF Nos. 17, 18, and 19 respectively); the Motion to Dismiss for Failure to State a Claim, Brief in Support, and Appendix in Support, that Defendant Texas Workforce Commission (“TWC”) filed on September 3, 2024 (ECF Nos. 23, 24, and 25 respectively); and Response to TWC’s Motion to Dismiss that Plaintiff Briaunna Daniels (“Daniels”) filed September 10, 2024 (ECF No. 27). This case was referred to the undersigned automatically pursuant to Special Order 3 on June 17, 2024. ECF No. 4. After considering the pleadings and applicable legal authorities, the undersigned RECOMMENDS that United States District Judge Reed O’Connor GRANT Defendants’ Motions to Dismiss (ECF Nos. 17, 23), DISMISS the claims against GMF WITH PREJUDICE, and DISMISS the claims against TWC WITHOUT PREJUDICE. I. BACKGROUND Daniels originally brought this case in the 48th Judicial District Court of Tarrant County, Texas, in June 2023. Id. at 10. GMF removed the case to this Court on July 6, 2023 in Civil Action No. 4:23-cv-00691-P. The Court dismissed that case without prejudice on October 13, 2023. ECF No. 9 in No. 4:23-cv-00691-P. Daniels also attempted to appeal her state case by filing a notice of appeal in state court on April 5, 2024. ECF No. 1 at 10. The Court of Appeals for the Second Appellate District of Texas at Fort Worth dismissed the appeal for want of jurisdiction because there was no final judgment or appealable order in the state court case that GMF previously

appealed to this Court. Id. Daniels filed the instant case on June 17, 2024, alleging that GMF violated the Family Medical Leave Act of 1993 (“FMLA”) and the Families First Coronavirus Response Act (“FFCRA”). ECF No. 1. On July 9, 2024, the Court ordered Daniels to file an amended complaint that set forth a short and plain statement supporting her cause of action under Federal Rules of Civil Procedure 8(a) and 15(a) and Local Civil Rule 7.1. ECF No. 10. Daniels filed the amended complaint on July 19, 2024. ECF No. 11. Taken together, the complaints state that GMF terminated Daniels’ employment on January 7, 2022. ECF Nos. 1, 11. GMF allegedly violated Daniels’ FMLA and FFCRA rights because she

“was out on a pre-existing and pre-approved FMLA leave dated between December 27, 2021 through January 7, 2022[,]” and GMF “did not offer [her] any sick paid leave nor did [it] offer any emergency family and medical leave act of expansion underneath the FFCRA to care for her mother.” ECF Nos. 11 at 1 and 1 at 2. Daniels also alleges that she applied for a managerial position and “was racially discriminated by [GMF] … as she was told by [GMF] to withdraw [] her application due to her race and skin color.” ECF No. 1 at 1. In its Motion, GMF argues that the FMLA’s statute of limitations bars Daniels’ FMLA claims and that her amended complaint fails to state a claim upon which relief can be granted under Federal Rule of Civil Procedure 12(b)(6). Id. GMF further asserts that the FFCRA was not in effect at the time of the alleged violation, so Daniels cannot recover under that statute. Id. In its Motion, TWC argues that Daniels’ amended complaint is time-barred and fails to state a claim upon which relief can be granted, and that the Court lacks subject matter jurisdiction over Daniels’ claims. ECF No. 24. TWC also asserts that “[Daniels] makes no specific claims against TWC,” and that “there is no mention of TWC’s involvement other than in the prayer of relief.” ECF No. 23 at 8-9.

Daniels filed one response to both motions on September 10, 2024, and states that she timely filed her claims “within the 3-year statute of limitation,” and that her claims are “valid.” ECF No. 27 at 2, 3. II. LEGAL STANDARDS Federal Rule of Civil Procedure 12(b)(6) permits dismissal of complaints that fail to state a claim upon which relief can be granted. Fed. R. Civ. P. 12(b)(6). To state a viable claim for relief, a complaint must include sufficient factual allegations “to raise a right to relief above the speculative level.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007). In considering a Rule 12(b)(6) motion, courts must “take all well-pleaded facts as true, viewing them in the light most

favorable to the plaintiff . . . and ask whether the pleadings contain ‘enough facts to state a claim to relief that is plausible on its face.’” Yumilicious Franchise, LLC v. Barrie, 819 F.3d 170, 174 (5th Cir. 2016) (citing Twombly, 550 U.S. at 547). “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) (citing Twombly, 550 U.S. at 547). Rule 12(b)(1) of the Federal Rules of Civil Procedure allows a party to move for dismissal of a complaint based on lack of subject matter jurisdiction. Fed. R. Civ. P. 12(b)(1). Because “[f]ederal courts are courts of limited jurisdiction[, t]hey possess only that power authorized by Constitution and statute, which is not to be expanded by judicial decree.” Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994) (citations omitted). If a Court lacks subject matter jurisdiction, it must dismiss the action. Fed. R. Civ. P. 12(h)(3). In determining whether subject matter jurisdiction exists, a court “must presume that a suit lies outside this limited jurisdiction, and the burden of establishing federal jurisdiction rests on the party seeking the federal forum.”

Howery v. Allstate Ins. Co., 243 F.3d 912, 916 (5th Cir. 2001). “A case is properly dismissed for lack of subject matter jurisdiction when the court lacks the statutory or constitutional power to adjudicate the case.” CleanCOALition v. TXU Power, 536 F.3d 469, 473 (5th Cir. 2008) (quoting Home Builders Ass'n of Miss., Inc. v. City of Madison, 143 F.3d 1006, 1010 (5th Cir. 1998)). “When a Rule 12(b)(1) motion is filed in conjunction with other Rule 12 motions, the court should consider the Rule 12(b)(1) jurisdictional attack before addressing any attack on the merits.” Ramming v. United States, 281 F.3d 158, 161 (5th Cir. 2001) (citing Hitt v. City of Pasadena, 561 F.2d 606, 608 (5th Cir. 1977)). This “prevents a court without jurisdiction from prematurely dismissing a case with prejudice.” Id.

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Bluebook (online)
Daniels v. Texas Workforce Commission, Counsel Stack Legal Research, https://law.counselstack.com/opinion/daniels-v-texas-workforce-commission-txnd-2024.