Howard v. Arizona, State of

CourtDistrict Court, D. Arizona
DecidedApril 15, 2024
Docket2:23-cv-01087
StatusUnknown

This text of Howard v. Arizona, State of (Howard v. Arizona, State of) 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
Howard v. Arizona, State of, (D. Ariz. 2024).

Opinion

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

9 Rhonda Howard, No. CV-23-01087-PHX-ROS

10 Plaintiff, ORDER

11 v.

12 State of Arizona, et al.,

13 Defendants. 14 15 Plaintiff Rhonda Howard previously worked for Defendant State of Arizona. 16 During her employment, Howard believes she was subjected to a hostile work environment 17 because of a disability, her race, and her sex. Defendant argues the hostile work 18 environment claim based on disability is barred by the Eleventh Amendment and the hostile 19 work environment claim based on race and sex is not supported by sufficient facts. 20 Defendant is correct but Plaintiff will be granted leave to amend. 21 BACKGROUND 22 As of April 2022, Howard was working at the Arizona Department of Economic 23 Security. (Doc. 1 at 3). At that time, Howard had cancer and was taking intermittent time 24 off to undergo radiation treatments. On April 11, 2022, Howard attended an in-office 25 training. A colleague sat next to Howard during that training. Following the training, the 26 colleague spoke with Howard in front of their supervisor. According to the complaint, the 27 colleague stated she had looked at Howard’s “staff photo” and concluded Howard was a 28 “white girl.” But having sat next to Howard, the colleague stated Howard appeared to be 1 “brown.” The colleague added that if she had recognized Howard before sitting next to 2 her, the colleague “would not have sat near” Howard. 3 Howard responded to these comments by asking if the colleague “had an issue with 4 her.” (Doc. 1 at 3). The colleague responded she “does have a problem and it’s Howard’s 5 cancer.” (Doc. 1 at 3). In particular, the colleague was “bothered” by Howard informing 6 other employees when she would take time off for radiation treatments. Finally, the 7 colleague stated Howard was “an imbecile . . . small minded . . . unwomanly . . . [and] no 8 one likes [her].” (Doc. 1 at 3). The supervisor witnessed these statements but “simply 9 stated that ‘we all have things we are stressed about.’” (Doc. 1 at 4). 10 After Howard’s interaction with her colleague, Howard’s supervisor required 11 Howard “message [the supervisor], rather than the whole team to let her know when 12 [Howard] would be away for radiation treatment.” (Doc. 1 at 4). This resulted in Howard 13 being “seen as the problem.” According to Howard, this was a “different protocol than 14 everyone else” used when taking time off from work. Howard believes that differential 15 treatment was due to a protected characteristic, such as her disability, sex, or race. (Doc. 16 1 at 4). 17 Based on these events, Howard filed the present suit asserting two hostile work 18 environment claims against Defendant State of Arizona.1 One claim is brought under the 19 Americans with Disabilities Act (“ADA”), and the other claim is brought under Title VII. 20 Defendant seeks dismissal of both claims arguing the Eleventh Amendment bars the ADA 21 claim and the Title VII claim is not supported by sufficient factual allegations. 22 ANALYSIS 23 I. The Eleventh Amendment Bars the ADA Claim 24 Defendant argues Howard’s ADA claim is barred by the Eleventh Amendment. 25 Plaintiff disagrees but does not provide any meaningful analysis of the authority cited by 26 Defendant. 27 1 Plaintiff also named the Arizona Department of Economic Security as a defendant but 28 now concedes that agency is a “non-jural entity and consents to [its] dismissal.” (Doc. 11 at 6). 1 In general, the Eleventh Amendment prevents individuals from suing states in 2 federal court. Bd. of Trustees of Univ. of Alabama v. Garrett, 531 U.S. 356, 363 (2001). 3 However, “Congress may abrogate the States’ Eleventh Amendment immunity when it 4 both unequivocally intends to do so and act[s] pursuant to a valid grant of constitutional 5 authority.” Id. In 2001, the Supreme Court held “Congress did not validly abrogate the 6 States’ sovereign immunity from suit by private individuals for money damages under Title 7 I” of the ADA.2 Id. at 374 n.9. It is undisputed Howard’s “hostile work environment” 8 claim is brought under Title I of the ADA.3 Howard does not offer any argument why the 9 holding in Garrett should not apply. Therefore, Howard’s ADA claim is barred by the 10 Eleventh Amendment. 11 II. Title VII Hostile Work Environment Claim Lacks Supporting Facts 12 The Eleventh Amendment does not bar Title VII claims. Bolden-Hardge v. Off. of 13 California State Controller, 63 F.4th 1215, 1221 (9th Cir. 2023) (noting Title VII 14 “abrogates states’ sovereign immunity”). Thus, Defendant seeks dismissal of Howard’s 15 Title VII hostile work environment claim by arguing the complaint’s factual allegations 16 are not sufficient to state a claim for relief. 17 To state a viable hostile work environment claim, Howard was required to allege 18 facts showing she was “subjected to verbal or physical conduct” based on a protected 19 characteristic, the conduct was unwelcome, and the conduct was “sufficiently severe or 20 pervasive to alter the conditions of [her] employment and create an abusive work 21 environment.” Galdamez v. Potter, 415 F.3d 1015, 1023 (9th Cir. 2005). That final 22 element requires allegations Howard’s “work environment was both subjectively and 23 objectively hostile.” Id. Determining whether a work environment was sufficiently hostile 24 2 “The ADA contains five titles: Employment (Title I), Public Services (Title II), Public 25 Accommodations and Services Operated by Private Entities (Title III), Telecommunications (Title IV), and Miscellaneous Provisions (Title V).” Zimmerman v. 26 Oregon Dep’t of Just., 170 F.3d 1169, 1172 (9th Cir. 1999). Howard’s ADA claim is brought under Title I. 27 3 The Ninth Circuit has not yet determined whether “hostile work environment claims are cognizable under the ADA.” Denning v. Cnty. of Washoe, 799 F. App’x 547 (9th Cir. 28 2020). But even if such a claim exists, the Eleventh Amendment bars it against nonconsenting states. 1 involves looking “to all of the circumstances, including the frequency, severity, and nature 2 (i.e., physically threatening or humiliating as opposed to merely verbally offensive) of the 3 conduct.” Id. “The required severity of the conduct varies inversely with its pervasiveness 4 and frequency.” Id. 5 Title VII is not meant as “a general civility code” and “sporadic use of abusive 6 language, gender-related jokes, and occasional teasing” are not sufficient to establish a 7 hostile work environment claim. Fried v. Wynn Las Vegas, LLC, 18 F.4th 643, 648 (9th 8 Cir. 2021). This standard has precluded claims involving offensive conduct that did not 9 permeate the workplace. For example, a female employee alleged a hostile work 10 environment claim based on another employee referring “to women generally as ‘bitches’ 11 and ‘histrionics.’” Id. (quoting Kortan v. California Youth Auth., 217 F.3d 1104, 1107 (9th 12 Cir. 2000)). That was not sufficient. In another case, a female Chinese American alleged 13 her coworkers referred to her as “China woman” and she saw them “pulling their eyes back 14 with their fingers in an attempt to imitate or mock the appearance of Asians.” Id. (citing 15 Manatt v.

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

Related

Board of Trustees of Univ. of Ala. v. Garrett
531 U.S. 356 (Supreme Court, 2001)
United States v. Kristen Gilbert
229 F.3d 15 (First Circuit, 2000)
Li Li Manatt v. Bank of America, Na
339 F.3d 792 (Ninth Circuit, 2003)
Arlene Galdamez v. John Potter, Postmaster General
415 F.3d 1015 (Ninth Circuit, 2005)
Davis v. Team Electric Co.
520 F.3d 1080 (Ninth Circuit, 2008)
Vincent Fried v. Wynn Las Vegas, LLC
18 F.4th 643 (Ninth Circuit, 2021)
Brianna Bolden-Hardge v. California State Controller
63 F.4th 1215 (Ninth Circuit, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
Howard v. Arizona, State of, Counsel Stack Legal Research, https://law.counselstack.com/opinion/howard-v-arizona-state-of-azd-2024.