Farmer v. United Parcel Service Co.

CourtDistrict Court, W.D. Kentucky
DecidedJanuary 23, 2025
Docket3:24-cv-00460
StatusUnknown

This text of Farmer v. United Parcel Service Co. (Farmer v. United Parcel Service Co.) is published on Counsel Stack Legal Research, covering District Court, W.D. Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Farmer v. United Parcel Service Co., (W.D. Ky. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY LOUISVILLE DIVISION

JASON FARMER, ) ) Plaintiff, ) Civil Action No. 3:24-CV-460-CHB ) v. ) ) UNITED PARCEL SERVICE CO., and ) MEMORANDUM OPINION AND UNITED PARCEL SERVICE, INC., ) ORDER ) Defendants. )

*** *** *** *** This matter is before the Court on Defendants United Parcel Service Co. and United Parcel Service, Inc.’s, Motion to Dismiss, [R. 5]. Plaintiff Jason Farmer responded, [R. 10 (Plaintiff’s Amended Response to Defendants’ Motion to Dismiss)], and Defendants replied, [R. 13 (Defendants’ Reply in Support of Their Motion to Dismiss)]. The matter stands submitted for review. For the following reasons, Defendants’ Motion to Dismiss will be denied without prejudice. I. BACKGROUND Plaintiff Joseph Farmer, a now-fifty-year-old pilot, brought the instant employment discrimination action after being terminated by his employer. See generally [R. 1-2 (Complaint)]. As an initial matter, the Court notes that Plaintiff sues two entities, United Parcel Service Co. (“UPS Co.”) and United Parcel Service, Inc. (“UPS Inc.”), but it is not clear from the Complaint or the briefing which entity employed Plaintiff. In his Complaint, he alleges that UPS Inc. was his employer. Id. ¶ 3 (“The Plaintiff was employed by the United Parcel Service, Inc . . .”). However, Defendants dispute this in a footnote, saying “United Parcel Service, Inc. is the corporate entity that operates the UPS small package operation. [Plaintiff] was not employed by United Parcel Service, Inc. at any point.” [R. 5-1, p. 1 n.1]. In support, Defendants provide a declaration by David Smith, an employee of United Parcel Service, Co. See [R. 5-1, p.1 n.1 (citing [R. 5-2 (Smith Decl.)])]. However, the Court cannot consider this declaration at the motion to dismiss stage. See Jackson v. City of Columbus, 194 F.3d 737, 745 (6th Cir. 1999), abrogated on other grounds by Swierkiewicz v. Sorema N. A., 534 U.S. 506 (2002) (“[A]s a general rule, matters outside the

pleadings may not be considered in ruling on a 12(b)(6) motion to dismiss.” (quoting Weiner v. Klais & Co., 108 F.3d 86, 88 (6th Cir. 1997)); see also infra § II. Defendants do not expand on this argument in the body of their motion, and Plaintiff did not directly address it in his response. Plaintiff did, however, state he was employed by UPS Co. in his response brief and made no mention of UPS Inc. See [R. 10, p. 1]. Accordingly, when the Court refers to his employer, UPS, it refers to UPS Co. The Court will not further address this issue and will not dismiss UPS Inc. at this time. However, it will order Plaintiff to file a status report as to whether he pursues any claims against UPS Inc. Plaintiff’s Complaint asserted the following claims: “wrongful termination: age

discrimination in violation of Ky. Rev. Stat. § 344.040” (Count I), [R. 1-2, ¶¶ 43–50 (statutory citations updated)]; and “wrongful termination: disability discrimination in violation of Ky. Rev. Stat. § 344.040” (Count II), id. ¶¶ 51–57 (statutory citations updated).1 As to relief, Plaintiff seeks “(a) injunctive relief in the form of an order that Defendant cease its discriminatory practices and reinstate the Plaintiff in comparable employment [and] (b) money damages for back pay, front pay, and humiliation and embarrassment.” Id. at 13 (Prayer for Relief) (cleaned up).2

1 Plaintiff states in his Response that his “claims arise under state or federal law.” [R. 10, p. 2 (emphasis added)]. The Complaint, however, only states claims arising under Kentucky state law. See [R. 1-2]. 2 To the extent the page number listed on a filing differs from the page number assigned by the Court’s electronic docketing system, the Court refers to the page number assigned by the docketing system. According to the Complaint, UPS hired the plaintiff on May 6, 2019. [R. 1-2, ¶ 7]. Before beginning his training with UPS, Plaintiff underwent a double hip replacement surgery necessitated by a congenital birth defect. Id. ¶¶ 9–10. As a result, Plaintiff’s regular security screenings at the airport took longer than his peers’ and often included additional screenings after going through the standard metal detectors which led to verbal reprimands. Id. ¶¶ 12–16. Plaintiff

was also criticized, in general, “for being slow when completing tasks,” despite not taking longer than the allotted time per task on the proficiency exam. Id. ¶ 28. According to Plaintiff, although he “improved significantly” over the course of his training and “received numerous positive comments,” he was “often criticized for his techniques, despite the fact that the techniques [he] employed . . . were required by the manual established by [the airplane manufacturer] and UPS.” Id. ¶¶ 17–18. Moreover, Plaintiff generally alleges he was given conflicting and inaccurate feedback on “multiple instances” and he “did not receive the same level of coaching and accurate feedback from training personnel that candidates under forty years of age received” or that “candidates without a disability received.” Id. ¶¶ 30–32.

Plaintiff was terminated by UPS in November 2019. Id. ¶¶ 38–40. Mr. Wells, the only other pilot over forty, was also terminated. Id. ¶ 37. Plaintiff finally alleges a subsequent job offer from another employer was rescinded after UPS shared his training records, “which were not accurately representative of his performance and [were] negatively affected by the disparate treatment he received in training.” Id. ¶¶ 41–42. Plaintiff originally filed his Complaint in the Jefferson County Circuit Court in Jefferson County, Kentucky. [R. 1-2, p. 1]. Defendants removed the case to federal court under 28 U.S.C. §§ 1441 and 1446 on the basis of diversity jurisdiction pursuant to 28 U.S.C. § 1332(a)(1) because Plaintiff is a citizen of Utah and Defendants are citizens of Delaware, Georgia, and Ohio and the amount in controversy exceeds $75,000.3 See [R. 1, ¶¶ 8–18]. Defendants then filed their Motion to Dismiss, [R. 5], which is now fully briefed. See [R. 10]; [R. 13]. The matter stands ready for review. II. LEGAL STANDARD Rule 12 of the Federal Rules of Civil Procedure provides grounds upon which a defendant

may move to dismiss a claim. Relevant here are Rules 12(b)(1) and 12(b)(6). See [R. 5, p. 1]. First, under Rule 12(b)(1), a defendant may move to dismiss a claim for lack of subject matter jurisdiction. Under Rule 12(b)(6), a party may move for dismissal for “failure to state a claim upon which relief may be granted.” A challenge under Rule 12(b)(1) is either a “facial attack” or a “factual attack.” Gentek Bldg. Prod., Inc. v. Sherwin-Williams Co., 491 F.3d 320, 330 (6th Cir. 2007) (citations omitted).

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Farmer v. United Parcel Service Co., Counsel Stack Legal Research, https://law.counselstack.com/opinion/farmer-v-united-parcel-service-co-kywd-2025.