Henry v. Alabama State Department of Education (MAG+)

CourtDistrict Court, M.D. Alabama
DecidedMarch 31, 2023
Docket2:21-cv-00107
StatusUnknown

This text of Henry v. Alabama State Department of Education (MAG+) (Henry v. Alabama State Department of Education (MAG+)) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Henry v. Alabama State Department of Education (MAG+), (M.D. Ala. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION

WANDA HENRY, ) ) Plaintiff, ) ) ) v. ) CASE NO. 2:21-CV-107-WKW ) [WO] ALABAMA STATE ) DEPARTMENT OF EDUCATION, ) et al., ) ) Defendants. )

MEMORANDUM OPINION AND ORDER This is an employment discrimination case. Plaintiff Wanda Henry alleges that, in violation of Title VII, she was fired from her job as a Cosmetology and Automotive Education Specialist at the Alabama State Department of Education (ALSDE) because she is a woman and because she complained about discriminatory harassment. She also brings various state-law tort claims. Notably, Henry is representing herself in this action as a pro se plaintiff despite efforts to obtain counsel. To date, she has filed a complaint, an amended complaint, which was found to be a shotgun pleading, and a second amended complaint, which is currently operative. Pending before the court is Defendants ALSDE, Eric Mackey, Daniel Boyd, Tommy Glasscock, and Jennifer Burt’s motion to dismiss the amended complaint for failing to state any viable claim (Doc. # 55). On February 2, 2023, the Magistrate Judge filed a Recommendation (Doc. # 62) to which Henry filed an objection (Doc. # 64). The Recommendation

advised that all of Henry’s federal claims be dismissed with prejudice and for the court to decline to exercise supplemental jurisdiction over her state-law claims. For the reasons that follow, the Recommendation is due to be adopted in part and rejected

in part. Ultimately, the court concludes: (1) that the Title VII claims against all Defendants except ALSDE be dismissed with prejudice; (2) that the Title VII hostile-work-environment claim against ALSDE be dismissed with prejudice; (3) that the Title VII termination claims based on sex discrimination and retaliation

brought against ALSDE be dismissed without prejudice; and (4) that the state-law claims be dismissed without prejudice. Dismissing a claim “with prejudice” functionally means that the claim cannot

be brought again, either in an amended complaint or in a different case. Dismissing a claim “without prejudice” functionally means that the claim can be reasserted again either in an amended complaint or in a different case. Here, for the claims that are dismissed without prejudice, Plaintiff Wanda

Henry will be granted leave to file a further amended complaint on or before April 14, 2023. That means Henry is being given the opportunity to bring her Title VII retaliation, Title VII sex-discrimination, and state-law claims again in this case. If

Henry files a third amended complaint, it should include the factual detail that she includes in her objection, but that is not in her second amended complaint. Compare Objection to Recommendation (Doc. # 64) with Second Amended Complaint (Doc.

# 54). I. JURISDICTION AND VENUE This court has jurisdiction over Henry’s Title VII claims under its federal

question jurisdiction. 28 U.S.C. § 1331; Arbaugh v. Y&H Corp., 546 U.S. 500, 515 (2006). The court may exercise supplemental jurisdiction over her related state-law claims because they share a common nucleus of operative fact with her Title VII claims. 28 U.S.C. § 1367; Womack v. Carrol Cnty. Ga., 840 F. App’x 404, 407

(11th Cir. 2020) (citing Parker v. Scrap Metal Processors, Inc., 468 F.3d 733, 743 (11th Cir. 2006)). II. STANDARD OF REVIEW

A party’s timely written objections to a magistrate judge’s report and recommendation require this court’s de novo review of those portions of the report to which the party objects. See 28 U.S.C. § 636(b); see also Marsden v. Moore, 847 F.2d 1536, 1548 (11th Cir. 1988) (“Frivolous, conclusive, or general objections need

not be considered by the district court.”). After completing its review, applying the same standard as the magistrate judge, the court may accept, reject, or modify the report, in whole or in part. See 28 U.S.C. § 636(b). Here, the Magistrate Judge used the appropriate motion-to-dismiss standard for a motion brought under Federal Rule of Civil Procedure 12(b)(6): To survive a

Rule 12(b)(6) motion to dismiss, a complaint must contain factual allegations sufficient “to raise a right to relief beyond the speculative level.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007). “Threadbare recitals of the elements of a cause

of action, supported by mere conclusory statements” are insufficient to state a claim. Ashcroft v. Iqbal, 566 U.S. 662, 678 (2009) (quoting Twombly, 556 U.S. at 555). To determine whether a plaintiff has stated a claim, the court should first “eliminate any allegations in the complaint that are merely legal conclusions” and then determine

whether the well-pleaded factual allegations of the complaint—assuming their veracity—plausibly give rise to an entitlement to relief. Amer. Dental Assoc. v. Cigna Corp., 605 F.3d 1283, 1290 (11th Cir. 2010) (internal quotation and citation

omitted). “The plausibility standard is met only where the facts alleged enable ‘the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.’” Franklin v. Curry, 738 F.3d 1246, 1251 (11th Cir. 2013) (quoting Twombly, 550 U.S. at 556).

Federal courts must “show a leniency to pro se litigants not enjoyed by those with the benefit of a legal education.” GJR Invs., Inc. v. Cnty. Of Escambia, Fla., 132 F.3d 1359, 1369 (11th Cir. 1998) (italics removed). A document filed pro se is

“to be liberally construed,” and a pro se complaint, “however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (internal quotations omitted). However,

the leniency shown to pro se plaintiffs “does not give a court license to serve as de facto counsel for a party or to rewrite an otherwise deficient pleading in order to sustain an action.” GJR Inv., Inc., 132 F.3d at 1369. A pro se complaint must still

be dismissed if it fails to state a claim on which relief may be granted. See, e.g., Osahar v. U.S. Postal Serv., 297 F. App’x 863, 864 (11th Cir. 2008); Albrata v. Advan, Inc., 490 F.3d 826, 834 (11th Cir. 2007). III. FACTUAL BACKGROUND

Because the court ultimately reaches its decision based on facts brought forth in the objection—that were not in the operative complaint—the court will not write two lengthy factual narratives (one based solely on the second amended complaint,

and one based on that complaint as clarified by the objection).

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Henry v. Alabama State Department of Education (MAG+), Counsel Stack Legal Research, https://law.counselstack.com/opinion/henry-v-alabama-state-department-of-education-mag-almd-2023.