Hollis v. Randstad North America Incorporated

CourtDistrict Court, D. Arizona
DecidedJune 25, 2025
Docket2:25-cv-02144
StatusUnknown

This text of Hollis v. Randstad North America Incorporated (Hollis v. Randstad North America Incorporated) 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
Hollis v. Randstad North America Incorporated, (D. Ariz. 2025).

Opinion

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

9 Chambala J. Hollis, No. CV-25-02144-PHX-JJT

10 Plaintiff, ORDER

11 v.

12 Randstad North America Incorporated, et al., 13 Defendants. 14 15 At issue is pro se Plaintiff Chambala J. Hollis’s Application to Proceed in District 16 Court Without Prepaying Fees or Costs (Doc. 2). Having determined that Plaintiff does not 17 have the means to pay the Court’s fees in this case, the Court will grant the Application. 18 However, as set forth below, upon screening Plaintiff’s Complaint (Doc. 1, Compl.) pursuant 19 to 28 U.S.C. § 1915(e)(2), the Court finds that the Complaint fails to state many of the claims 20 raised. The Court therefore dismisses most of the Complaint with leave for Plaintiff to file 21 an Amended Complaint if he can cure the pleading defects identified in this Order. 22 I. LEGAL STANDARDS 23 A. 28 U.S.C. § 1915(e)(2) 24 For cases in which a party is permitted to proceed in forma pauperis—that is, the 25 party lacks the means to pay court fees—Congress provided that a district court “shall 26 dismiss the case at any time if the court determines” that the “allegation of poverty is untrue” 27 or that the “action or appeal” is “frivolous or malicious,” “fails to state a claim on which 28 relief may be granted,” or “seeks monetary relief against a defendant who is immune from 1 such relief.” 28 U.S.C. § 1915(e)(2). Section 1915(e) applies to all in forma pauperis 2 proceedings. Lopez v. Smith, 203 F.3d 1122, 1129 (9th Cir. 2000). “It is also clear that section 3 1915(e) not only permits but requires a district court to dismiss an in forma pauperis 4 complaint that fails to state a claim.” Id. at 1127. 5 B. Federal Rule of Civil Procedure 8 6 Under Federal Rule of Civil Procedure 8(a)(2), a complaint must include “a short 7 and plain statement of the claim showing that the [plaintiff] is entitled to relief.” A plaintiff 8 must allege “enough facts to state a claim to relief that is plausible on its face.” Bell Atl. 9 Corp. v. Twombly, 550 U.S. 544, 570 (2007). “A claim has facial plausibility when the 10 plaintiff pleads factual content that allows the court to draw the reasonable inference that 11 the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 12 (2009) (citing Twombly, 550 U.S. at 556). A dismissal for failure to state a claim can be 13 based on either (1) the lack of a cognizable legal theory or (2) insufficient facts to support a 14 cognizable legal claim. Balistreri v. Pacifica Police Dep’t, 901 F.2d 696, 699 (9th Cir. 1990). 15 II. ANALYSIS 16 In the Complaint, Plaintiff alleges the following. In April 2025, Defendant Randstad 17 North America, Inc.—a staffing company—placed him to work the Thursday to Monday 18 schedule at a warehouse operated by Defendant GXO Logistics Supply Chain, Inc. (Compl. 19 at 4–5.) In the approximately 10 days he worked at GXO before his termination, he “[a]s a 20 Black employee . . . was denied access to required safety and other training while non-Black 21 agency employees were granted access using company equipment to train.” (Compl. at 6.) 22 Specifically, although Plaintiff saw a Caucasian employee log out of the training laptop so 23 that a Hispanic employee could start her safety training videos, Plaintiff did not get access 24 to a training laptop during his first or second week of work. (Compl. at 10.) His supervisor, 25 Kristopher Whalen, explained “either, ‘There isn’t enough laptops, or wait until next week 26 or he needs to order more laptops.” (Compl. at 11.) 27 Around April 28, Plaintiff was assigned to the outbound/inbound dock area, 28 supervised by Christopher Garcia, and issues arose. (Compl. at 8.) Plaintiff used a broom 1 handle to remove plastic from Google data racks, and Garcia confronted Plaintiff, accusing 2 him of damaging the plastic wrapping and ripping wires on the data racks. (Compl. at 8 & 3 nn.1, 3.) Plaintiff did not agree that this method was inappropriate because Whalen 4 “permitted all employees to use our best judgment to improvise certain work duties as long 5 as we wear [Personal Protective Equipment].” (Compl. at 8.) Plaintiff alleges the machines 6 themselves were not damaged and “the 8 data racks were taken up to the data center on the 7 2nd floor for soft replacement.” (Compl. at 8 n.3.) But Whalen and Garcia reported the 8 resulting confrontation to the Randstad account manager, Ashlee Morales, and Plaintiff 9 was terminated. (Compl. at 9.) Whalen and Garcia announced that Plaintiff was fired 10 because he “cursed them out,” “use[d] a broom handle and tore or damaged the wires from 11 the new Google Data Racks and refused to work” (Compl. at 10), some of which Plaintiff 12 alleges is false (Compl. at 8). After his termination, Whalen and Garcia downloaded video 13 of Plaintiff’s work to “use[] as a training/what not to do video.” (Compl. at 11.) When 14 Plaintiff returned to Randstad’s office to seek other employment, a Randstad employee told 15 Plaintiff he “can no longer work for Randstad again based upon false accusations of the 16 client.” (Compl. at 7.) 17 Plaintiff has now filed this suit raising claims against GXO and Randstad of racial 18 discrimination and retaliation under 42 U.S.C. § 1981, defamation under the “First 19 Amendment of the U.S. Constitution and Arizona Law,” and “breach of contract/implied 20 covenant of good faith/and negligence.” (Compl. at 11–15.) Plaintiff seeks $50 million in 21 damages and $5 million in punitive damages. (Compl. at 3.) 22 A. Section 1981 Claim 23 A section 1981 suit requires a plaintiff to allege facts supporting a showing that 24 racial discrimination by each defendant was the but-for cause of his alleged injury. See 25 Comcast Corp. v. Nat’l Ass’n of African-American Owned Media, 140 S.Ct. 1009 (2020). 26 Here, Plaintiff alleges he suffered damages resulting from his termination by GXO as well 27 as Randstad’s later refusal to place him in other employment. But the Complaint contains 28 no facts raising an inference that his termination by GXO or refusal to rehire by Randstad 1 were based on his race. While Plaintiff alleges he witnessed non-Black employees 2 engaging in training at GXO while he was not yet able to complete his training, his alleged 3 injuries are unrelated to his lack of access to training during his first two weeks of work at 4 GXO. Moreover, the temporary lack of access to training by itself is not sufficient to 5 constitute a hostile work environment. As for the employers’ alleged actions—termination 6 and refusal to rehire—that resulted in his alleged injury, Plaintiff cannot state a section 7 1981 claim by simply alleging he is Black and Defendants terminated him and then failed 8 to rehire him, even if he thinks the termination was not warranted. The pleading standard 9 requires Plaintiff to allege sufficient facts showing that his race was the but-for cause of 10 his termination and the refusal to rehire. See Twombly, 550 U.S. at 555.

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Hollis v. Randstad North America Incorporated, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hollis-v-randstad-north-america-incorporated-azd-2025.