Hair v. Autonation USA Corporation

CourtDistrict Court, M.D. Florida
DecidedJuly 7, 2025
Docket6:25-cv-00359
StatusUnknown

This text of Hair v. Autonation USA Corporation (Hair v. Autonation USA Corporation) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hair v. Autonation USA Corporation, (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION

PATRICK HAIR,

Plaintiff,

v. Case No: 6:25-cv-359-CEM-LHP

AUTONATION USA CORPORATION,

Defendant

REPORT AND RECOMMENDATION TO THE UNITED STATES DISTRICT COURT:

Before the Court is Plaintiff’s Application to Proceed in District Court Without Prepaying Fees or Costs (Long Form), which has been construed as a motion for leave to proceed in forma pauperis. Doc. No. 2. The matter has been referred to the undersigned and is ripe for review. Upon consideration, the undersigned will respectfully recommend that the motion (Doc. No. 2) be denied without prejudice and Plaintiff’s complaint (Doc. No. 1) be dismissed with leave to amend. I. BACKGROUND. On March 3, 2025, Plaintiff Patrick Hair, appearing pro se, instituted this

action against Defendant Autonation USA Corporation, by filing a Complaint for Employment Discrimination and Retaliation. Doc. No. 1. Plaintiff asserts claims of discrimination, hostile work environment, and retaliation under Title VII of the

Civil Rights Act (“Title VII”) and the related Florida Civil Rights Act (“FCRA”), and a claim for failure to accommodate his disability (diabetes) in violation of the Americans With Disabilities Act (“ADA”). Id.1 In sum, Plaintiff’s claims stem from his employment with Defendant during an unidentified time period, with

Plaintiff alleging the following facts in toto: A. Discriminatory Employment Practices

7. Defendant engaged in discriminatory hiring and onboarding practices, delaying Plaintiff’s employment start date despite confirming his hire. Plaintiff was treated less favorably than similarly situated employees who did not share his protected characteristics.

8. Defendant’s HR department failed to communicate Plaintiff’s onboarding status, and management publicly undermined Plaintiff’s qualifications, making false and discriminatory statements.

B. Failure to Accommodate a Disability (ADA Violation)

9. Plaintiff, who has diabetes, requested a reasonable accommodation due to a documented health condition. Despite providing medical

1 At the beginning of the complaint, Plaintiff also references the Fair Labor Standards Act (“FLSA”), Doc. No. 1, at 1, but the FLSA is not further mentioned in the complaint. Accordingly, this report does not further address the FLSA. documentation, Defendant failed to accommodate Plaintiff’s medical needs and instead subjected him to harassment and retaliation.

10. Defendant’s management made derogatory comments regarding Plaintiff's medical condition and unfairly criticized his work attendance despite prior medical approval.

C. Hostile Work Environment and Retaliation

11. Plaintiff faced disparate treatment and favoritism, with management selectively assisting favored employees while undermining Plaintiff’s ability to make sales and earn commissions.

12. Plaintiff was subjected to intimidation, threats, and verbal abuse from both management and coworkers, including an incident where a manager balled his fists and warned Plaintiff to “keep his mouth closed.”

13. Defendant failed to protect Plaintiff from harassment despite multiple complaints, allowing a toxic work environment to persist.

D. Retaliation for Reporting Misconduct

14. Plaintiff reported discriminatory practices, workplace safety violations (OSHA), and predatory lending practices. In response, Defendant retaliated by isolating Plaintiff, restricting his job responsibilities, and suspending him under pre-textual reasons.

15. Following a customer complaint about an inflated interest rate (26.43%), Defendant faced an investigation. Plaintiff, who was involved in the transaction, was subsequently subjected to heightened scrutiny and retaliation, including attempts to sabotage his sales performance.

16. After requesting legal counsel during a performance hearing, Plaintiff was suspended again, demonstrating retaliatory intent by the employer.

E. Pattern of Favoritism and Unlawful Practices 17. Defendant engaged in predatory lending by inflating interest rates for customers, disproportionately affecting minority buyers. Plaintiff became aware of these practices and attempted to intervene on behalf of customers.

18. Defendant’s management encouraged covert misconduct, such as manipulating finance terms to dissuade customers from purchasing vehicles. Plaintiff witnessed fraudulent lending practices that led to a government agency investigation.

19. The employer protected employees who complied with unethical practices while retaliating against those who challenged unlawful behavior.

Id. at 2–3. The claims asserted under Title VII, the FCRA, and the ADA do not incorporate any of these specific facts but instead are stated in general terms. Id. at 3. Plaintiff seeks compensatory and punitive damages, injunctive relief, reinstatement or front pay, and fees and costs. Id. at 4. The complaint is unsigned. See id. at 4–6. Plaintiff submits with the complaint a “Witness List,” a “Description of Evidence,” and a Determination and Notice of Rights from the United States Equal Employment Opportunity Commission. Id. at 7–12. With the complaint, Plaintiff has also filed a motion to for leave to proceed in forma pauperis. Doc. No. 2. II. STANDARD OF REVIEW.

The Court must conduct a two-step inquiry when a plaintiff files a complaint and seeks leave to proceed in forma pauperis. First, the Court must evaluate the plaintiff’s financial status and determine whether he or she is eligible to proceed in forma pauperis. 28 U.S.C. § 1915(a)(1). Second, the Court must review the complaint pursuant to § 1915(e)(2) and dismiss the complaint if the action is

frivolous or malicious, the complaint fails to state a claim on which relief may be granted, or the complaint seeks monetary relief against a defendant who is immune from such relief. Id. § 1915(e)(2)(B)(i)–(iii).2 A complaint is frivolous within the

meaning of § 1915(e)(2)(B) if it “lacks an arguable basis either in law or in fact.” Neitzke v. Williams, 490 U.S. 319, 325 (1989). To avoid dismissal for failure to state a claim upon which relief can be granted, the allegations must show plausibility. Bell Atlantic Corp. v. Twombly, 550

U.S. 544, 557 (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) (citation omitted). “Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Id. A pro se complaint should be construed leniently, but a court does not have

“license . . . to rewrite an otherwise deficient pleading [by a pro se litigant] in order to sustain an action.” GJR Invs. v. Cty. of Escambia, Fla., 132 F.3d 1359, 1369 (11th

2 The statute governing proceedings in forma pauperis references actions instituted by prisoners, see 28 U.S.C. § 1915, but has been interpreted to apply to all litigants requesting leave to proceed in forma pauperis. Martinez v. Kristi Kleaners, Inc., 364 F.3d 1305, 1306 n.1 (11th Cir. 2004). Cir. 1998), overruled on other grounds by Iqbal,

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