Foley v. Express Support Home Care, LLC

CourtDistrict Court, E.D. North Carolina
DecidedAugust 20, 2024
Docket5:24-cv-00165
StatusUnknown

This text of Foley v. Express Support Home Care, LLC (Foley v. Express Support Home Care, LLC) is published on Counsel Stack Legal Research, covering District Court, E.D. North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Foley v. Express Support Home Care, LLC, (E.D.N.C. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA WESTERN DIVISION No. 5:24-cv-000165-FL-RN

Cynthia G. Foley,

Plaintiff,

Order & v. Memorandum & Recommendation

Express Support Home Care, LLC,

Defendants.

Plaintiff Cynthia G. Foley, proceeding pro se, brought this lawsuit to recover for employment- and disability-related discrimination she claims to have suffered while working for Express Support Home Care, LLC. Before the court is Foley’s request to pursue this action without paying the standard filing fee. D.E. 2. In connection with that request, the court must also assess the viability of her claims. While this opinion grants her request to avoid paying the filing fee, it also recommends that the District Court dismiss this action. Foley’s claims are subject to dismiss because she did not pursue her administrative remedies at the EEOC in a timely manner and she has named defendants who are not subject to suit under the laws that establish her claims. I. Background Foley began this action in March 2024 when she filed a complaint and a motion to be relieved from paying the filing fee. The court referred that motion to the undersigned shortly after its filing. As part of considering that motion, the court must also consider the viability of Foley’s claims. 28 U.S.C. § 1915(e). Foley’s Original Complaint listed three defendants in the caption: Express Support Home Care, LLC, the Austin Law Firm, and Jarold Johnston. Yet in the body of the document, it named Reggie Ogbonna, Patrick Ogbonna, John Austin, and Jarold Johnston as defendants. The Ogbonnas are the owners of Express Support Home Care, Austin is the company’s attorney, and

Johnston was one of Foley’s colleagues. Foley claimed Defendants discriminated against her based on her race, sex, national origin, and disability. The Original Complaint contained few supporting allegations other than that she injured her wrist and elbow in February 2020, that someone “abused [her] medical profiles[,]” and that she was relocated to a location that required her to drive 76 miles each way to work. Foley also attached several dozen pages of documents to her Original Complaint. After reviewing the Original Complaint, the court noted that her pleading did “not fully set out the facts underlying her claim.” June 13, 2024 Order at 1, D.E. 10. It ordered her to “file an amended complaint that sets out the facts supporting her claims in numbered paragraphs.” Id. And the court explained that “[t]he amended complaint should state, with specificity, the facts

underlying her claims and the actions each defendant took that she claims violated her rights.” Id. The Amended Complaint, however, provided little additional information. For example, the Amended Complaint referred to “the above-listed defendants” but it identified no one as a defendant. Nor did it clearly set out the facts supporting her discrimination claim. Instead, it discussed issues related to other matters like a worker’s compensation claim and a bankruptcy proceeding. So the court held a hearing with Foley to explain what the court needed her to provide to assess her claims. At the end of that hearing, the court ordered Foley to file a Second Amended Complaint and ordered the Clerk of Court to provide her with a form complaint for employment discrimination matters as well as the court’s guide for pro se litigants. In response, Foley filed three complaints. Two of those complaints are general form complaints for civil actions and the third is a form complaint for employment discrimination

actions. The court will refer to these documents collectively as the Second Amended Complaint. The documents name different individuals and entities as defendants in their captions, but they all name the same individuals as defendants in their bodies: the Ogbonnas, Johnston, and Austin. The allegations in these documents cover a lot of ground. There is discussion of Foley’s bankruptcy proceeding, a lawsuit filed in North Carolina state court, her unemployment benefits claim, and her workers compensation proceedings. As for her employment discrimination claims, Foley claims that the defendants violated her rights under Title VII of the Civil Rights Act of 1964 and the Americans with Disabilities Act. She maintains that they have done so by terminating her, failing to accommodate her disability, subjecting her to unequal terms and conditions of employment, and by retaliating

against her. And Foley believes the defendants discriminated against her because of her race, color, gender or sex, national origin, and her disability. She provides limited details about these allegations, but among the details provided was that she was terminated in March 2020 and filed her charge of discrimination with the EEOC in September 2023. Foley’s pleading also includes over 400 pages of other documents.

II. IFP Motion Foley asks the court to allow her to proceed with this action without paying the required filing fee and other costs associated with litigation (colloquially known as proceeding in forma pauperis or IFP). The court may grant her request if she submits an affidavit describing her assets and the court finds that she is unable to pay the filing fee. 28 U.S.C. § 1915. In assessing a request to proceed IFP, the court should consider whether the plaintiff can pay the costs associated with litigation “and still be able to provide himself and his dependents with the necessities of life.” Adkins v. E.I. DuPont de Nemours & Co., 335 U.S. 331, 339 (1948) (internal

quotations omitted). The court has reviewed Foley’s application and finds that she lacks the resources to pay the costs associated with this litigation. The court thus grants Foley’s motion (D.E. 2) and allows her to proceed IFP. III. Screening Under 28 U.S.C. § 1915 Along with determining whether Foley is entitled to IFP status, the court must also

analyze the viability of the claims contained in the Second Amended Complaint. 28 U.S.C. § 1915(e). The court reviews a complaint to eliminate claims that unnecessarily impede judicial efficiency and the administration of justice. The court must dismiss any portion of the complaint it determines is frivolous, 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. Id. § 1915(e)(2)(B). A complaint fails to state a claim upon which relief may be granted if it does not “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). The Supreme Court has explained that “[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.” Id.

Foley’s pro se status relaxes, but does not eliminate, the requirement that her pleading contain facially plausible claims. The court must liberally construe a pro se plaintiff’s allegations, but it “cannot ignore a clear failure to allege facts” that set forth a cognizable claim. Johnson v. BAC Home Loans Servicing, LP, 867 F. Supp. 2d 766, 776 (E.D.N.C. 2011).

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Related

Adkins v. E. I. DuPont De Nemours & Co.
335 U.S. 331 (Supreme Court, 1948)
Zipes v. Trans World Airlines, Inc.
455 U.S. 385 (Supreme Court, 1982)
National Railroad Passenger Corporation v. Morgan
536 U.S. 101 (Supreme Court, 2002)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Amr Fawzy v. Wauquiez Boats SNC
873 F.3d 451 (Fourth Circuit, 2017)
Baird ex rel. Baird v. Rose
192 F.3d 462 (Fourth Circuit, 1999)
Johnson v. Bac Home Loans Servicing, LP
867 F. Supp. 2d 766 (E.D. North Carolina, 2011)

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Bluebook (online)
Foley v. Express Support Home Care, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/foley-v-express-support-home-care-llc-nced-2024.