Erin Carling v. Sacks Counseling, LLC

CourtDistrict Court, S.D. Texas
DecidedJuly 12, 2024
Docket4:24-cv-01413
StatusUnknown

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

Bluebook
Erin Carling v. Sacks Counseling, LLC, (S.D. Tex. 2024).

Opinion

UNITED STATES DISTRICT COURT July 12, 2024 Nathan Ochsner, Clerk SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

ERIN CARLING, § § Plaintiff, § § v. § CIVIL ACTION NO. 4:24-cv-1413 § SACKS COUNSELING, LLC, § § Defendant. §

MEMORANDUM AND RECOMMENDATION

Pending before the Court1 is Defendant Sacks Counseling, LLC’s (“Defendant”) Motion to Dismiss (ECF No. 13), Defendant’s Motion for More Definite Statement (ECF No. 14), Plaintiff Erin Carling’s (“Plaintiff”) Motion for Hearing (ECF No. 16), and Plaintiff’s Motion for Extension of Time (ECF No. 21).2 Based on a review of the motion and applicable law, the Court RECOMMENDS Defendant’s Motion to Dismiss (ECF No. 13) be GRANTED and Plaintiff’s Complaint (ECF No. 1) be DISMISSED WITH PREJUDICE as to Defendant Sacks Counseling, LLC. The Court FURTHER RECOMMENDS Defendant’s Motion for More Definite Statement (ECF No.

1 On May 1, 2024, this case was referred to the Undersigned for all purposes pursuant to 28 U.S.C. § 636(b)(1)(A) and (B) and Federal Rule of Civil Procedure 72. (ECF No. 5). 2 On May 31, 2024, this Court issued a Memorandum and Recommendation on Plaintiff’s Motion for Preliminary Injunction (ECF No. 4), recommending that it be denied. (ECF No. 8). 14), Plaintiff’s Motion for Hearing (ECF No. 16), and Plaintiff’s Motion for Extension of Time (ECF No. 21) be DENIED AS MOOT.

I. Background This is an employment discrimination case brought under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e, et seq. (ECF No. 1). On April 14, 2024, pro se Plaintiff filed suit against Defendant, alleging she

was discriminated against based on her race. (Id.). Plaintiff attached the charge of discrimination she filed with the Equal Employment Opportunity Commission (“EEOC”) to her complaint. (Id. at 10–12). In the charge of discrimination, Plaintiff provided details on various conflicts with her

employer and her mental health struggles. (Id.). On June 21, 2024, Defendant filed the instant Motion to Dismiss pursuant to Federal Rule of Civil Procedure (“Rule”) 12(b)(6). (ECF No. 13). Since then, Plaintiff has filed (1) a Notice to the Court communicating to the

Court that she was working on her response (ECF No. 15); (2) a Motion for a Hearing wherein she requested help interpreting the law (ECF No. 16); (3) a Letter requesting help a second time (ECF No. 17); (4) an Exhibit containing “racial discrimination pictures” (ECF No. 18); (5) an “Amended Complaint”

wherein Plaintiff simply “added” two parties to the case without restating her causes of action (ECF No. 19); and (6) a Motion for Extension of Time to amend

2 the joint discovery case management plan (ECF No. 21). On July 11, 2024, Plaintiff filed her Response to Defendant’s Motion to Dismiss. (ECF No. 24).

II. Legal Standard Rule 12(b)(6) provides for dismissal of an action for “failure to state a claim upon which relief can be granted.” FED. R. CIV. P. 12(b)(6). When considering a motion to dismiss, a court should construe the allegations in the

complaint favorably to the pleader and accept as true all well-pleaded facts. Sullivan v. Leor Energy, LLC, 600 F.3d 542, 546 (5th Cir. 2010). In the Fifth Circuit, motions to dismiss under Rule 12(b)(6) are viewed with disfavor and rarely granted. Lormand v. U.S. Unwired, Inc., 565 F.3d 228, 232 (5th Cir.

2009). To survive dismissal, a complaint must plead “enough facts to 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). However, a court is not bound to accept legal conclusions couched as factual allegations. Papasan v. Allain, 478 U.S. 265, 286 (1986). Although all

reasonable inferences will be resolved in favor of a plaintiff, a plaintiff must plead “specific facts, not mere conclusory allegations.” Tuchman v. DSC

3 Commc’ns Corp., 14 F.3d 1061, 1067 (5th Cir. 1994); see also Firefighters’ Ret. Sys. v. Grant Thornton, L.L.P., 894 F.3d 665, 669 (5th Cir. 2018) (“Although a

complaint does not need detailed factual allegations, the allegations must be enough to raise a right to relief above the speculative level . . . .”) (internal quotations omitted)). “‘Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.’” Firefighters’ Ret.

Sys., 894 F.3d at 669 (quoting Iqbal, 556 U.S. at 678). “The court is not required to conjure up unpled allegations or construe elaborately arcane scripts to save a complaint.” Santerre v. Agip Petroleum Co., Inc., 45 F. Supp. 2d 558, 568 (S.D. Tex. 1999) (internal quotations omitted).

To determine whether to grant a Rule 12(b)(6) motion, a court may only look to allegations in a complaint to determine their sufficiency. Id.; Atwater Partners of Tex. LLC v. AT & T, Inc., No. 2:10-cv-175-TJW, 2011 WL 1004880, at *1 (E.D. Tex. Mar. 18, 2011). “A court may, however, also consider matters

outside the four corners of a complaint if they are incorporated by reference, items subject to judicial notice, matters of public record, orders, items appearing in the record of a case, and exhibits attached to a complaint whose authenticity is unquestioned.” Joubert on Behalf of Joubert v. City of Houston,

No. 4:22-cv-3750, 2024 WL 1560015, at *2 (S.D. Tex. Apr. 10, 2024).

4 Importantly here, courts hold “pro se plaintiffs to a more lenient standard than lawyers when analyzing complaints, but pro se plaintiffs must

still plead factual allegations that raise the right to relief above the speculative level.” Chhim v. Univ. of Tex. at Austin, 836 F.3d 467, 469 (5th Cir. 2016) (citing Taylor v. Books A Million, Inc., 296 F.3d 376, 378 (5th Cir. 2002)); see also Ganheart v. Brown, 740 F. App’x 386, 389 (5th Cir. 2018) (“Pro se

complaints are held to less stringent standards than formal pleadings drafted by lawyers but are nonetheless insufficient if they contain only labels and conclusions, or a formulaic recitation of the elements of a cause of action.” (quotations and alterations omitted)).

“A plaintiff need not make out a prima facie case of discrimination in order to survive a Rule 12(b)(6) motion.” English v. Purdue, 777 F. App’x 94, 99 (5th Cir. 2019) (quoting Raj v. La. State Univ., 714 F.3d 322, 329–30 (5th Cir. 2013)). But a plaintiff must “plead sufficient facts on all of the ultimate

elements of a disparate treatment claim to make his case plausible.” Chhim, 836 F.3d at 470.

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Related

Tuchman v. DSC Communications Corp.
14 F.3d 1061 (Fifth Circuit, 1994)
Hamilton v. Southwestern Bell Telephone Co.
136 F.3d 1047 (Fifth Circuit, 1998)
Byers v. Dallas Morning News, Inc.
209 F.3d 419 (Fifth Circuit, 2000)
Taylor v. Books a Million, Inc.
296 F.3d 376 (Fifth Circuit, 2002)
Goldstein v. MCI Worldcom
340 F.3d 238 (Fifth Circuit, 2003)
Lormand v. US Unwired, Inc.
565 F.3d 228 (Fifth Circuit, 2009)
Sullivan v. Leor Energy, LLC
600 F.3d 542 (Fifth Circuit, 2010)
McDonnell Douglas Corp. v. Green
411 U.S. 792 (Supreme Court, 1973)
Papasan v. Allain
478 U.S. 265 (Supreme Court, 1986)
Swierkiewicz v. Sorema N. A.
534 U.S. 506 (Supreme Court, 2002)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Jackson v. Watkins
619 F.3d 463 (Fifth Circuit, 2010)
Raj v. Louisiana State University
714 F.3d 322 (Fifth Circuit, 2013)
Santerre v. Agip Petroleum Co., Inc.
45 F. Supp. 2d 558 (S.D. Texas, 1999)
Nicole Burton v. Freescale Semiconductor, Inc., et
798 F.3d 222 (Fifth Circuit, 2015)

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