House v. TH Foods, Inc.

CourtDistrict Court, D. Nevada
DecidedMarch 25, 2025
Docket2:24-cv-01326
StatusUnknown

This text of House v. TH Foods, Inc. (House v. TH Foods, Inc.) 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
House v. TH Foods, Inc., (D. Nev. 2025).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 Preston House, Case No.: 2:24-cv-01326-JAD-NJK

4 Plaintiff Order Granting in Part Defendant’s 5 v. Motion to Dismiss

6 TH Foods, Inc., [ECF Nos. 24, 47, 55, 57]

7 Defendant

8 Plaintiff Preston House sues his former employer TH Foods, Inc. under Title VII of the 9 Civil Rights Act of 1964 and Nevada’s state-law corollary.1 The employer moves to dismiss 10 House’s first-amended complaint, arguing that its allegations are too thin to state any claim for 11 relief, and to the extent that House pleads a constructive-discharge claim, it is barred because he 12 failed to exhaust it.2 House’s counsel filed an opposition3 and then withdrew, and House has 13 since filed several supplemental oppositions, which the employer moves to strike.4 I find that 14 House has pled a plausible claim for retaliation, but I grant the motion to dismiss any other 15 theories as insufficiently pled. And because the court’s inquiry on a motion to dismiss is 16 confined to the four corners of the complaint, I deny House’s request to supplement his 17 opposition with outside-the-record evidence, and I grant the employer’s motions to strike his 18 additional filings. 19 20 21 1 ECF No. 18. 22 2 ECF No. 24. 23 3 ECF No. 33. 4 ECF Nos. 47, 57. 1 Discussion 2 District courts employ a two-step approach when evaluating a complaint’s sufficiency on 3 a Federal Rule of Civil Procedure 12(b)(6) motion to dismiss. The court must first accept as true 4 all well-pled factual allegations in the complaint, recognizing that legal conclusions are not

5 entitled to the assumption of truth.5 Mere recitals of a claim’s elements, supported by only 6 conclusory statements, are insufficient.6 The court must then consider whether the well-pled 7 factual allegations state a plausible claim for relief.7 A claim is facially plausible when it 8 contains facts that allow the court to draw a reasonable inference that the defendant is liable for 9 the alleged misconduct.8 A complaint that does not permit the court to infer more than the mere 10 possibility of misconduct has “alleged—but not shown—that the pleader is entitled to relief,” 11 and it must be dismissed.9 12 House frames his complaint as two causes of action: (1) “Discrimination under Federal 13 Anti-Discrimination Statutes in Violation of Title VII of the Civil Rights Act of 1964, as 14 Amended,” and (2) “Violation of Nevada Statutory Protections.”10 The employer characterizes

15 these causes of action to include claims for constructive discharge, racial discrimination, and 16 retaliation. It argues that the constructive-discharge claim must be dismissed because House 17 failed to exhaust it as part of his administrative claim with the Nevada Equal Rights Commission 18 (NERC) or the Equal Employment Opportunity Commission (EEOC), and even if he had 19

20 5 Ashcroft v. Iqbal, 556 U.S. 662, 678–79 (2009). 21 6 Id. 7 Id. at 679. 22 8 Id. 23 9 Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). 10 ECF No. 18 at 4–5. 1 properly exhausted it, the claim must be dismissed because House has not pled facts to state a 2 constructive-discharge claim. They challenge his racial-discrimination and retaliation claims as 3 insufficient in myriad ways.11 House’s counseled, two-page opposition provides no substantive 4 response to any of these points and offers to amend the complaint to fix any perceived

5 deficiency—but without providing a proposed amended complaint as this district’s local rules 6 require.12 House attempts to make up that deficiency by late-filing exhibits that he believes 7 would support his claims.13 8 A. House has pled a plausible retaliation claim. 9 To state a prima facie case of retaliation, a plaintiff must show (1) that he “undertook a 10 protected activity under Title VII,” (2) defendants subjected him to an adverse employment 11 action, and (3) that there exists “a causal link between the two.”14 House’s complaint states a 12 plausible claim for retaliation. Construed in the light most favorable to him, House’s allegations 13 state that he reported his manager’s racially motivated comments and “thereafter was treated 14 with contempt by” the employer “in retaliation for complaining of these racially motivated

15 comments.”15 That contempt manifested itself as several “false and contrived” disciplinary 16 actions for bogus reasons,16 and House was ultimately placed on a performance improvement 17 18 19

20 11 ECF No. 24. 21 12 L.R. 15-1(a). 13 ECF Nos. 46, 55, 56. 22 14 Vasquez v. Cnty. of Los Angeles, 349 F.3d 634, 646 (9th Cir. 2003). 23 15 ECF No. 18 at 3. 16 Id. 1 plan (PIP) “for making complaints about his treatment at work.”17 At this early stage of 2 litigation, this is enough to state a claim for retaliation. 3 B. House has failed to state facts to support a racial-discrimination claim. 4 The same cannot be said for House’s racial-discrimination claim. To state a claim for

5 racial discrimination, a plaintiff must show that: (1) he is a member of a protected class (2) who 6 was qualified for his position (3) but was subject to an adverse employment action (4) for a 7 discriminatory reason or to which similarly situated individuals outside his protected class 8 weren’t subjected.18 While House’s allegations show that he is an “African-American” male and 9 thus a member of a protected class and that he “performed his job satisfactorily,”19 no fact 10 suggests that he was treated differently from non-African-American employees or suffered any 11 adverse action due to his race. At most, he states that his manager made the comment that 12 “Preston lives in the hood,” and he characterizes this as a “racially motivated comment[].”20 13 And he recounts various “false and contrived” disciplinary actions taken against him.21 14 Although House states that he “was discriminated against and retaliated against because of his

15 racial ethnicity,” this is an entirely conclusory statement and he offers no facts from which that 16 motivation can be inferred. So I grant the motion to dismiss his racial-discrimination claim. 17 18 19 20 17 Id. at 4. 21 18 Chuang v. Univ. of Cal. Davis, Bd. of Trs., 225 F.3d 1115, 1123–24 (9th Cir. 2000) (citing McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802 (1973)). 22 19 ECF No. 18 at 3–4. 23 20 Id. at 3. 21 Id. 1 C. House’s allegations also fall short of stating a constructive-discharge claim. 2 The third and final theory of employer liability that appears to be raised by House’s 3 complaint is constructive discharge. He alleges that the retaliatory acts against him, including 4 the false accusations, bogus disciplinary actions, and placement on a PIP “created working

5 conditions so intolerable and aggravated toward” him “that any reasonable person in [his] 6 employment position with Defendant would feel compelled to resign . . . .”22 The employer 7 moves to dismiss this claim on two grounds: failure to exhaust administrative remedies and 8 insufficiency of the factual allegations.23 9 To the extent that the employer seeks dismissal based on a failure to exhaust, I deny the 10 motion.

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House v. TH Foods, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/house-v-th-foods-inc-nvd-2025.