Hamdard v. Swift Transportation Company of Arizona LLC

CourtDistrict Court, D. Arizona
DecidedMarch 14, 2025
Docket2:24-cv-00943
StatusUnknown

This text of Hamdard v. Swift Transportation Company of Arizona LLC (Hamdard v. Swift Transportation Company of Arizona LLC) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hamdard v. Swift Transportation Company of Arizona LLC, (D. Ariz. 2025).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Ahmad Shoaib Hamdard, No. CV-24-00943-PHX-DLR

10 Plaintiff, ORDER

11 v.

12 Swift Transportation Company of Arizona LLC, 13 Defendant. 14 15 Pending before the Court is Defendant Swift Transportation Company of Arizona’s 16 (“Swift”) motion to dismiss (Doc. 9) Plaintiff Ahmad Shoaib Hamdard’s Complaint (Doc. 17 1). The motion is fully briefed.1 (Docs. 13, 16.) For the reasons set forth herein, the Court 18 grants the motion. 19 I. Background2 20 Swift is one of the largest freight transportation companies in North America, and 21 it employees approximately 25,100 driving associates. (Doc. 1 ¶¶ 24, 26.) Hamdard is an 22 Afghan citizen of Afghan national origin who, while living in Afghanistan from 2017 23 through 2020, maintained an Afghan driver’s license. (Id. ¶¶ 28, 30–32.) In 2020, Hamdard 24 moved from Afghanistan to the United States on a non-immigrant K-1 fiancé visa. (Id. ¶ 25 31.) He obtained an Oregon driver’s license in January 2022 and later that same year, 26 1 Oral argument is denied because the motions are adequately briefed, and oral 27 argument will not help the Court resolve the issues presented. See Fed. R. Civ. P. 78(b); LRCiv. 7.2(f). 28 2 The following facts are drawn from the allegations in the Complaint (Doc. 1), which the Court accepts as true for the purposes of this order. 1 obtained his Commercial Driver’s License (“CDL”). (Id. ¶ 35, 38.) After obtaining his 2 CDL, Hamdard applied for a position as a driver with Swift (though the position he applied 3 for did not require a CDL). (Id. ¶ 39.) 4 Amid Hamdard’s application process, a Swift employee informed Hamdard that 5 Swift has a policy requiring any applicant for a driver position to have held a United States 6 state-issued driver’s license for at least twelve months prior to applying. (Id. ¶ 41.) At that 7 point, Hamdard had his Oregon driver’s license for only ten months. He was told when he 8 applied for the job, that, for that reason, his application would be turned down. (Id.) 9 Another employee told Hamdard that, but for his lack of a state-issued driver’s license for 10 the requisite period, Hamdard was exactly the kind of employee that Swift needed and that 11 Hamdard would have been a good driver for Swift. (Id. ¶ 48.) 12 Hamdard brings suit on behalf of himself and a putative class of non-U.S. national 13 origin applicants to Swift who did not have a U.S. state-issued driver’s license for at least 14 twelve months prior to their application but who did have an intentional driver’s license 15 for that time. (Id. ¶ 10.) Hamdard alleges three counts: (1) national origin discrimination in 16 violation of Title VII of the Civil Rights Act of 1964; (2) national origin discrimination in 17 violation of the Arizona Civil Rights Act (“ACRA”); and (3) alienage discrimination in 18 violation of the Civil Rights Act of 1871, 42 U.S.C. § 1981.3 (Id. at 12–16.) Swift moves 19 to dismiss all counts for failure to state a claim under Rule 12(b)(6). (Doc. 9 at 2.) 20 II. Legal Standard 21 To survive dismissal for failure to state a claim pursuant to Rule 12(b)(6), a 22 complaint must include sufficient facts to demonstrate that the claim is plausible on its 23 face. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009); Bell Atlantic Corp. v. Twombly, 550 U.S. 24 544, 570 (2007). For Rule 12(b)(6) motions, the Court accepts all well-pled factual 25 allegations as true and construes those allegations in a light most favorable to the non- 26 moving party. Cousins v. Lockyer, 568 F.3d 1063, 1067 (9th Cir. 2009). Still, the Court is 27 3 Hamdard exhausted his administrative remedies, filing a charge of discrimination 28 with the Equal Employment Opportunity Commission and obtaining his Notice of Right to Sue prior to filing suit in this Court. (Id. ¶¶ 49–50.) 1 not required “to accept as true a legal conclusion couched as a factual allegation.” Iqbal, 2 556 U.S. at 678 (quoting Twombly, 550 U.S. at 555). If the plaintiff fails to nudge his claim 3 “across the line from conceivable to plausible,” the Court will dismiss it. Twombly, 550 4 U.S. at 570. 5 III. Analysis 6 The Court analyzes Swift’s arguments for dismissal of Counts I and II together.4 7 The Court then considers Swift’s argument for dismissal of Count III. 8 a. Counts I and II 9 Title VII and the ACRA prohibit an employer from using a “particular employment 10 practice that causes a disparate impact on the basis of . . . national origin” unless the 11 employer can demonstrate that the practice is “job related” and “consistent with business 12 necessity.” 42 U.S.C. § 2000e-2(k)(1)(A)(i); accord. Ariz. Rev. Stat. Ann. § 41-1463. A 13 disparate-impact claim involves an employment practice that is neutral on its face but “that 14 in fact fall[s] more harshly on one group than another[.]” Raytheon Co. v. Hernandez, 540 15 U.S. 44, 52 (2003) (quotation omitted). To plead a disparate-impact claim under Title VII 16 and ACRA, a plaintiff must plausibly allege: (1) a significant disparate impact on a 17 protected group; (2) the specific employment practice, policy, or selection criteria at issue; 18 and (3) a causal relationship between the challenged practice, policy, or criteria and the 19 disparate impact. Bolden-Hardge v. Off. of Cal. State Controller, 63 F.4th 1215, 1227 (9th 20 Cir. 2023). 21 At the pleadings stage of a disparate impact claim, the plaintiff need not support his 22 claim with statistics where the disparate impact is obvious. Id. Swift contends that Hamdard 23 fails to plausibly allege the first element of his national origin discrimination claims 24 because he failed to include statistical allegations demonstrating a disparate impact. (Doc. 25 9 at 4.) Hamdard responds that the disparate impact is obvious, so statistical allegations are 26 unnecessary. (Doc. 13 at 9.)

27 4 “[T]he [ACRA] is ‘generally identical’ to Title VII, and therefore ‘federal Title VII case law [is] persuasive in the interpretation of [the ACRA].’” Bodett v. Coxcom, 366 28 F.3d 736, 742 (9th Cir. 2004) (quoting Higdon v. Evergreen Int’l Airlines, Inc., 1673 P.2d 907, 909–10 n.3 (1983)). 1 The Court agrees with Swift: Hamdard fails to allege an obvious disparate impact 2 and thus does not plausibly allege a disparate-impact claim. Hamdard defines the affected 3 class as Swift applicants of “non-U.S. national origin.” (Doc. 1 ¶ 10.) As Swift points out, 4 “national origin” under Title VII means “the country where a person was born, or more 5 broadly, the country from which his or her ancestors came.” Espinoza v. Farah Mfg. Co., 6 414 U.S. 86, 88 (1973). If Hamdard means that the class is specifically those applicants 7 who were born outside of the United States, he has not alleged that. Applicants of “non- 8 U.S. national origin” would include applicants of Hispanic, Italian, Nigerian, French, 9 Haitian, and Japanese descent—just to name a few—regardless of whether those applicants 10 were born or ever lived in another country. In fact, the only people who would not be 11 included in the class as defined by the allegations are Native Americans.

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Hamdard v. Swift Transportation Company of Arizona LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hamdard-v-swift-transportation-company-of-arizona-llc-azd-2025.