Kandt v. Garden City, Kansas, City of

CourtDistrict Court, D. Kansas
DecidedMarch 19, 2025
Docket2:23-cv-02043
StatusUnknown

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

Bluebook
Kandt v. Garden City, Kansas, City of, (D. Kan. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRIT OF KANSAS

KRISTIN E. KANDT,

Plaintiff,

v. Case No. 23-2043-DDC-TJJ CITY OF GARDEN CITY, KANSAS,

Defendant.

MEMORANDUM AND ORDER

This is a case about disability discrimination. But the issue at hand is procedural. Plaintiff Kristin Kandt sues Garden City, Kansas over discriminatory treatment she allegedly experienced while serving as Garden City’s Municipal Judge. Kandt contends that Garden City denied her repeated requests for accommodation and retaliated against her for pursuing them. After the city terminated Kandt’s employment, she filed charges with the EEOC in August 2022. Around that time, the city began its search for her replacement, and Kandt reapplied. The city declined to interview her. So, Kandt filed a second charge with the EEOC—this time, over the city’s failure to interview or hire her for the Municipal Judge role. But, the city contends, Kandt can’t add claims based on that second charge now because she waited too long. The Department of Justice (DOJ) issued a right-to-sue notice on August 17, 2023. Kandt then had 90 days to file a claim. But Kandt didn’t file her Second Amended Complaint (Doc. 35)—adding the new claim—until July 2, 2024, almost ten months later. The reason for the delay, she maintains, is that she didn’t receive the right-to-sue notice until June 2024. The city moves to dismiss Kandt’s new claim under Federal Rule of Civil Procedure 12(b)(6). Doc. 36. It argues that Kandt’s claim is time barred because she failed to sue within 90 days of the notice in the EEOC’s August 17, 2023 right-to-sue letter. Doc. 37 at 1. Kandt

responds that she didn’t receive the DOJ’s right-to-sue notice until June 2024, “through no fault of [her] own.” Doc. 38 at 5. And she attached a string of emails to her Second Amended Complaint to demonstrate nonreceipt. See Doc. 35-2. So, Kandt maintains, the court should equitably toll the 90-day limitations period. Doc. 38 at 3. The court determines it must presume receipt of the notice in August 2023. And it concludes Kandt hasn’t shouldered her burden to establish that equitable tolling applies here. The court thus grants the city’s Motion to Dismiss Plaintiff’s Additional Claims in Second Amended Complaint (Doc. 36), as explained below. I. Factual Background

These facts come from Kandt’s initial Complaint (Doc. 1) and Second Amended Complaint (Doc. 35). The court accepts plaintiff’s “well-pleaded facts as true, view[s] them in the light most favorable to [her], and draw[s] all reasonable inferences from the facts” in her favor. Brooks v. Mentor Worldwide LLC, 985 F.3d 1272, 1281 (10th Cir. 2021). This Order recites just the facts required to decide the Partial Motion to Dismiss. The Garden City Municipal Judge Position In February 2020, plaintiff Kristin Kandt accepted the role of Municipal Judge for the City of Garden City, Kansas. Doc. 35 at 3, 4 (Second Am. Compl. ¶¶ 13, 24). Before becoming Municipal Judge, Kandt was an accomplished attorney with more than 25 years of legal experience. Id. at 3 (Second Am. Compl. ¶¶ 13–14). Kandt’s Disability and Accommodations Kandt is disabled. Id. (Second Am. Compl. ¶¶ 15–17). She has primary immune deficiency, a chronic condition that requires regular medical treatment and substantial

precautions to mitigate health risks. Id. So, throughout her time as Municipal Judge, she required accommodations—both to receive care for her disability, and to avoid exacerbating it. Id. Kandt maintains that during her time as Municipal Judge, her colleagues at the city denied her repeated requests for accommodations because of her disability. Id. at 4, 5 (Second Am. Compl. ¶¶ 27–29, 35). As a result, her health and wellbeing diminished. Id. at 9 (Second Am. Compl. ¶ 63). In January 2021, the city put her on administrative leave and, in February 2022, terminated her employment. Id. at 7, 8 (Second Am. Compl. ¶¶ 48, 54–56). Kandt’s Initial EEOC Charges Kandt filed discrimination charges with the EEOC on August 21, 2022. Id. at 8 (Second

Am. Compl. ¶ 57). The EEOC issued a “Determination and Notice of Rights”—commonly called a “right-to-sue” letter—on January 17, 2023. Doc. 1-1 at 1. The notice informed Kandt she’d have 90 days to file suit over her charges. Id. And on February 2, 2023, Kandt timely filed her Complaint. 1 Doc. 1 (Compl.). The Complaint contained five separate counts alleging that Garden City had violated federal and state law. Id. at 15–26 (Compl. ¶¶ 1–47). When Kandt filed her Complaint, she attached the EEOC right-to-sue notice and its corresponding

1 Kandt filed her Complaint anonymously, under the pseudonym “Jane Doe.” Doc. 1 at 1 (Compl.). She requested anonymity because of the private medical information at issue in the case. Id. at 1 n.1. The court later informed Kandt “that she would be required to file and prevail on a motion to proceed by pseudonym if she wished to do so. Doc. 23. Kandt then advised the court that she didn’t intend to file such a motion. Id. The court thus directed the parties and clerk to name Kandt in all future filings. Id. The court thus uses her name here. explanatory documents to her Complaint. Doc. 1-1. On March 25, 2024, this court dismissed one of her claims—an equal protection claim—without disposing of the others. Doc. 25 at 13. Kandt’s Second Amended Complaint Kandt filed a Second Amended Complaint on July 2, 2024. Doc. 35 (Second Am. Compl.). It included two counts under the Americans with Disabilities Act (“ADA”) and ADA

Amendments Act of 2008 (“ADAAA”), known collectively as the “ADA/ADAAA.” Id. at 9–13 (Second Am. Compl. ¶¶ 65–90). Kandt asserts two claims: disability discrimination and retaliation. Id. While the first count reasserted allegations from her initial Complaint, the second count introduced on a new theory of recovery: that Garden City had retaliated against her by declining to interview or hire her for the Municipal Judge opening in August 2022. Id. at 12–13 (Second Am. Compl. ¶¶ 83–88). She claims the city retaliated against her for: complaining about instances of discrimination; requesting that the city reasonably accommodate her; and filing charges with the EEOC that resulted in her first right-to-sue notice. Id. at 12–13 (Second Am. Compl. ¶¶ 82–86).

She attached several documents to her Second Amended Complaint: (1) the January 2023 “Determination and Notice of Rights” from the EEOC and its corresponding informational packet, Doc. 35-1 at 1–5; (2) a second right-to-sue notice—this one issued by the DOJ and dated August 17, 2023—and its attendant information sheet, Doc. 35-2 at 3–6; (3) an EEOC notice dated August 16, 2023, informing her that the EEOC had forwarded her second charge to the DOJ, id. at 8; and (4) an email exchange consisting of three parts, id. at 1–2, 7. Next, the court describes the three email exchanges. Email #1: The Right-to-Sue Notice In one email—dated August 17, 2023—-DOJ Senior Investigator Celeste Adams- Simmons contacted Kandt at the address “keklaw@sbcglobal.net” to deliver the DOJ-issued right-to-sue notice. Doc. 35-2 at 2. Adams-Simmons apparently attached the notice. /d. In the body of the email, Adams-Simmons said Kandt would have 90 days from her “receipt of the Notice” to file suit. /d. The email requested that Kandt “reply ‘received’ as acknowledgement.” Id. While addressed to Kandt, Adams-Simmons sent “CCs” to Stephanie Williams, an Enforcement Supervisor in the EEOC’s Kansas City office, among others. /d. at 1-2. The court reprints the entire email here:

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