Harris v. Clark County School District

CourtDistrict Court, D. Nevada
DecidedMarch 1, 2024
Docket2:23-cv-00259
StatusUnknown

This text of Harris v. Clark County School District (Harris v. Clark County School District) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Harris v. Clark County School District, (D. Nev. 2024).

Opinion

3 UNITED STATES DISTRICT COURT

4 DISTRICT OF NEVADA

5 * * *

6 LEROY HARRIS, Case No. 2:23-cv-00259-MMD-MDC

7 Plaintiff, ORDER v. 8 CLARK COUNTY SCHOOL DISTRICT, 9 Defendant. 10 11 I. SUMMARY 12 Pro se Plaintiff Leroy Harris sued his former employer, Defendant Clark County 13 School District, under the Americans With Disabilities Act of 1990, 42 U.S.C. § 12131, et 14 seq. (“ADA”). (ECF No. 27.) This order resolves the currently pending motions (ECF Nos. 15 29, 33, 40, 43) and gives Plaintiff an opportunity to file a second amended complaint. 16 However, the Court admonishes Plaintiff that it will dismiss this case with prejudice if he 17 does not file a second amended complaint consistent with this order within 30 days. The 18 Court further admonishes Plaintiff that he must attempt to familiarize himself with the 19 Federal Rules of Civil Procedure, the Court’s Local Rules,1 and all orders entered by the 20 Court or United States Magistrate Judge Maximiliano D. Couvillier, III. Compliance with 21 applicable procedural requirements going forward will make the Court better able to 22 adjudicate the merits of Plaintiff’s claims. 23 II. BACKGROUND 24 Plaintiff filed an initial Complaint against Defendant. (ECF No. 2.) Defendant 25 moved to dismiss it. (ECF No. 13.) In response, Plaintiff filed what appeared to be a 26 proposed amended complaint. (ECF No. 15.) Because Plaintiff is proceeding pro se, the 27

28 1United States District Court, District of Nevada, Local Rules of Practice (Last Amended Apr. 12, 2020), available at https://www.nvd.uscourts.gov/wp- 2 Defendant’s initial motion to dismiss as moot, and deemed the proposed amended 3 complaint the operative complaint. (ECF No. 25.) At the Court’s direction, the Clerk of 4 Court filed Plaintiff’s proposed amended pleading as the first amended complaint. (ECF 5 No. 27 (“FAC”); see also ECF No. 25.) The FAC remains the operative complaint in this 6 case. 7 In the FAC, Plaintiff alleges four claims for violation of the ADA. (ECF No. 27.) The 8 first claim focuses on alleged failure to accommodate his alleged disability because a 9 ramp he used to transport sports equipment to a physical education area was removed. 10 (Id. at 10.) His second claim focuses on allegations that the principal of the school where 11 he worked declined to rehire him in retaliation for him complaining about the removal of 12 the ramp. (Id. at 11.) Plaintiff’s third claim also appears to allege the same retaliation 13 theory, but is titled ‘Unlawful Termination of Employment’ under a Nevada statute. (Id. at 14 12.) Plaintiff’s fourth claim alleges he was not hired for several jobs he applied for with 15 Defendant in the summer of 2020 because of his disability. (Id. at 12-13.) 16 Defendant moved to dismiss the FAC. (ECF No. 29.) In response to Defendant’s 17 motion, Plaintiff states that he stipulates to the dismissal of his first three claims alleged 18 in the FAC. (ECF No. 31 at 2.) However, he opposes dismissal of his fourth claim alleging 19 a failure to hire because of his disability. (Id.) That said, Plaintiff also discusses a 42 20 U.S.C. § 1983 claim for violation of his Fourteenth Amendment rights (id.)—indeed, much 21 of his responsive argument is devoted to arguing that his ‘fourth claim’ regarding violation 22 of his constitutional rights under Section 1983 should not be dismissed (id. at 10-12). In 23 reply, and among other arguments, Defendant points out in pertinent part that Plaintiff 24 cannot assert a Section 1983 claim “for violation of Title VII or ADA.” (ECF No. 32 at 7.) 25 Defendant further explains that this argument is only even relevant if Plaintiff had asserted 26 a Section 1983 claim in an operative pleading, and he has not. (Id. at 4 n.4.) 27 Next, Plaintiff filed a motion for summary judgment on his unasserted Section 1983 28 claim. (ECF No. 33.) Defendant responds that Plaintiff’s motion is premature for several 2 alternatively should be denied on its merits, and denied because it is based on a Section 3 1983 claim not asserted in the operative FAC. (ECF No. 36.)2 4 Defendant then filed a motion to stay the dispositive motion deadline, requesting 5 the Court stay all deadlines in the case until the Court adjudicates the motion to dismiss 6 it had previously filed. (ECF No. 40.) Plaintiff opposed this motion, and Defendant filed a 7 reply. (ECF Nos. 42, 45.) But apparently in part because the Court did not rule on that 8 motion before the dispositive motion deadline arrived, Defendant filed a precautionary3 9 motion for summary judgment on all Plaintiffs’ claims asserted in the FAC along with 10 Plaintiff’s unasserted Section 1983 claim. (ECF No. 43.) Plaintiff opposed that motion as 11 well. (ECF No. 48.) As of the date of entry of this order, the deadline for Defendant to file 12 its reply in support of its motion for summary judgment has not yet elapsed. (See id.) 13 III. DISCUSSION 14 The FAC is currently the operative complaint. (ECF No. 27.) Plaintiff consents to 15 the dismissal of the first three claims in it. (ECF No. 31 at 2.) Defendant’s motion to 16 dismiss (ECF No. 29) is accordingly granted as to those three claims regarding an alleged 17 denial of reasonable accommodations, and alleged failure to rehire Plaintiff in retaliation 18 for his requests for accommodation (ECF No. 27 at 10-12). 19 That leaves Plaintiff’s fourth claim for an alleged ADA violation regarding 20 Defendant’s decision not to hire him for eight jobs he applied for in the summer of 2020 21 because of his disability. (Id. at 12-13.) Defendant argues in pertinent part that the Court 22 must dismiss this claim because Plaintiff failed to sufficiently allege discrimination, instead 23 simply concluding in the pertinent section of the FAC that Defendant failed to rehire him 24 because of his disability. (ECF No. 29 at 13.) The Court agrees with Defendant. 25 /// 26 2Plaintiff filed a reply. (ECF No. 39.) 27 3Defendant repeatedly mentions how the outcome of the motion could depend on 28 whether and how the Court rules on its previously filed motions to dismiss and to stay the dispositive motion deadline. (See, e.g., ECF No. 43 at 11.) 2 disabled under the Act, (2) a ‘qualified individual with a disability,’ and (3) discriminated 3 against ‘because of” the disability.” Bates v. United Parcel Serv., Inc., 511 F.3d 974, 988 4 (9th Cir. 2007). Here, Plaintiff merely alleges in a conclusory fashion that he was not hired 5 because of his disability. (ECF No. 27 at 12-13.) But mere recitation of the elements does 6 not suffice without the accompanying, sufficient factual allegations that could state a 7 plausible claim. See, e.g., Franklin v. Adams & Assocs., Inc., 817 F. App’x 505, 506 (9th 8 Cir. 2020) (making similar findings). Indeed, the same pleading standards apply to ADA 9 claims as every other case in federal court. To survive a motion to dismiss, a complaint 10 must contain sufficient factual matter to “state a claim to relief that is plausible on its face.” 11 Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 12 544, 570 (2007)). Plaintiff has not done that in his FAC with respect to his fourth claim. 13 The Court thus also grants Defendant’s motion to dismiss (ECF No. 29) as to Plaintiff’s 14 fourth claim regarding Defendant’s decision not to hire him for the various jobs he applied 15 for in the summer of 2020 (ECF No. 27 at 12-13).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Baker v. McCollan
443 U.S. 137 (Supreme Court, 1979)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Albright v. Oliver
510 U.S. 266 (Supreme Court, 1994)
Watters v. Wachovia Bank, N. A.
550 U.S. 1 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Trishan Air, Inc. v. Federal Insurance
635 F.3d 422 (Ninth Circuit, 2011)
Dougherty v. City of Covina
654 F.3d 892 (Ninth Circuit, 2011)
Jack Allen v. City of Beverly Hills
911 F.2d 367 (Ninth Circuit, 1990)
Plumeau v. School District #40
130 F.3d 432 (Ninth Circuit, 1997)
Bates v. United Parcel Service, Inc.
511 F.3d 974 (Ninth Circuit, 2007)

Cite This Page — Counsel Stack

Bluebook (online)
Harris v. Clark County School District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harris-v-clark-county-school-district-nvd-2024.