Douglas v. Onin Staffing, LLC

CourtDistrict Court, S.D. Mississippi
DecidedMarch 31, 2025
Docket3:24-cv-00157
StatusUnknown

This text of Douglas v. Onin Staffing, LLC (Douglas v. Onin Staffing, LLC) is published on Counsel Stack Legal Research, covering District Court, S.D. Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Douglas v. Onin Staffing, LLC, (S.D. Miss. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI NORTHERN DIVISION

ETORIA DOUGLAS,

Plaintiff,

v. CAUSE NO. 3:24-CV-157-CWR-ASH ONIN STAFFING, LLC, TOPRE AMERICA CORPORATION, and NISSAN NORTH AMERICA, INC.,

Defendants.

ORDER Before the Court are motions to dismiss filed by defendants Nissan North America, Inc.; Topre America Corporation; and Onin Staffing, LLC. Docket Nos. 8, 12, and 22. For the reasons that follow, Nissan’s motion will be granted, and Topre and Onin’s motions will be granted in part and denied in part. I. Factual and Procedural History Plaintiff Etoria Douglas was hired by Onin in February 2022 “and was assigned to work at the Nissan complex on a temp-to-perm basis for one of Nissan’s vendors, Topre.” Docket No. 1 ¶ 24. Douglas claims that one day, as she was being dropped off at work, Nathan Dubose, a Topre employee, addressed her sexually by saying “damn girl.” Docket No. 1-1 at 2. Douglas maintains that although she told Dubose she was not interested in him, he continued to harass her throughout the day. Dubose waited for Douglass outside the bathroom on a forklift and tried to get her in trouble at work by falsely reporting that her boyfriend pulled a gun on him. Douglas alleges that after she “reported the harassment . . . Human Resources at Topre

began looking for excuses to fire [her].” Docket No. 1 ¶ 28. She says Jackie, a Topre HR employee, “began assuming [she] was medically unable to work” and required her to miss work on two occasions. Id. ¶ 29. On the first occasion, Jackie sent Douglas “for a COVID test because she saw her sneeze.” Id. The second occasion occurred after Douglas had “suffered a minor knee sprain.” Id. ¶ 30. Jackie observed Douglas walking differently and asked her if she had been medically evaluated. Douglas told Jackie that she had been treated by a doctor and was released to work. She claims that Jackie insisted she provide a work release that

included “the words ‘no restrictions’ on it—despite the fact [Douglas’s initial work release] listed no restrictions.” Id. ¶ 31. Jackie then sent Douglas home and required her to get another evaluation before she could return to work. Topre terminated Douglas in June 2022 because she “had too many attendance points in the system.” Id. ¶ 32. Douglas, however, believes she was terminated because she reported Dubose’s conduct. She contends that her employment with Onin Staffing was also terminated when Onin failed to reassign her after she was dismissed from Topre, “despite the existence

of other available work.” Id. ¶ 33. Douglas subsequently filed suit against Nissan, Topre, and Onin asserting claims under the ADA (discrimination) and Title VII (sex discrimination, hostile work environment, and retaliation). Each defendant responded with a motion to dismiss. Their arguments are addressed below. II. Legal Standard To survive a Rule 12(b)(6) motion to dismiss, a complaint must “contain sufficient factual matter . . . to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556

U.S. 662, 678, (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570, (2007)). The complaint need not contain “detailed factual allegations,” but requires more than “[t]hreadbare recitals of the elements of a cause of action.” Id. A plaintiff must plead enough “factual content [to] allow[] the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. The court accepts the factual allegations as true and construes the complaint in the light most favorable to the plaintiff. Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986).

III. Discussion A. Nissan Nissan argues that Douglas has not plausibly alleged that it was her employer under the ADA or Title VII. To determine whether Nissan was Douglas’s employer, the Court must consider whether Nissan had the right to hire, fire, supervise, or set Douglas’s work schedule. Burton v. Freescale Semiconductor, Inc., 798 F.3d 222, 227 (5th Cir. 2015). The Court also considers whether Nissan paid Douglas’s “salary, withheld taxes, provided benefits, and set the terms

and conditions of [her] employment.” Id. (quotation marks omitted). The Court has considered these factors and finds that Douglas has not plausibly alleged that Nissan was her employer. Douglas states, in a conclusory manner, that her “work was directed by Nissan and/or Topre” and that “Nissan and Topre both had control over who was present at work and the duties assigned.” Docket No. 1 at ¶ 25. But Douglas does not allege facts to support her claims. See Williams v. Delta Zeta Sorority, No. CV 23-268-JWD- RLB, 2024 WL 1315863, at *7 (M.D. La. Mar. 26, 2024). To the contrary, she maintains that Onin “screened potential employees, . . . handled administrative tasks related to hiring and

paying employees,” and “had the power to prevent or end discrimination and harassment by . . . assigning her other work.” Id. Additionally, she does not allege that Dubose and Jackie were employed by Nissan; according to Douglas, they were “employee[s] of Topre.” Id. ¶¶ 26, 29. Accordingly, the Court will dismiss the claims against Nissan. B. Topre and Onin 1. ADA Discrimination Defendants first argue that Douglas fails to plausibly allege that she was terminated

because she was “regarded as” disabled. “The ADA provides protections for individuals who have a disability, had a disability, or are regarded as having a disability.” Lyons v. Katy Indep. Sch. Dist., 964 F.3d 298, 302 (5th Cir. 2020). A person is “regarded as” disabled when they are perceived as having a physical or mental impairment, regardless of “whether the impairment actually limits or is perceived to limit a major life activity.” 42 U.S.C. § 12102(3)(A). The ADA’s “regarded as” status does “not apply to impairments that are transitory and minor.” Id. § 12102(3)(B). “A transitory

impairment is an impairment with an actual or expected duration of 6 months or less.” Id. “Section 12102 does not define what types of impairments are minor, so courts determine whether an impairment is minor on a case-by-case basis considering factors such as symptoms, severity, the treatment required, the risk involved, and any surgical intervention anticipated or necessary.” Douglas v. Ben E. Keith Co., No. 3:19-CV-2824-BN, 2021 WL 3930086, at *5 (N.D. Tex. Sept. 1, 2021) (quotation marks omitted). Douglas’s alleged impairments are “covid and [the] knee injury.” Docket No. 21 at 3. Douglas does not allege that she actually had covid, only that Jackie required her to receive a covid test because she sneezed. Nor does she allege that her knee injury lasted or was

expected to last for any period of time. Rather, Douglas explains that she was treated by a doctor and released to work with no restrictions. Thus, the Court concludes that both of Douglas’s impairments were “objectively transitory and minor by her own admission, because the actual or expected duration of [her] impairment[s] . . . was [either] less than six months,” or lasted for no time at all. Lyons, 964 F.3d at 303; see Douglas, 2021 WL 3930086, at *5. Douglas does not allege any facts to the contrary. See Worrall v. River Shack LLC, No. 3:22-CV-0392-B, 2022 WL 3371345, at *5 (N.D.

Tex. Aug.

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