Kelly v. O'Malley

CourtDistrict Court, E.D. Missouri
DecidedSeptember 25, 2025
Docket4:24-cv-00214
StatusUnknown

This text of Kelly v. O'Malley (Kelly v. O'Malley) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kelly v. O'Malley, (E.D. Mo. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

JASON L. KELLY, ) ) Plaintiff, ) ) v. ) Case No. 4:24 CV 214 RWS ) MARTIN O’MALLEY, ) Commissioner of Social Security, ) ) Defendant, )

MEMORANDUM AND ORDER

Plaintiff Jason L. Kelly’s complaint asserts that he was subjected to employment discrimination by the Social Security Administration (the “SSA”) when his application for a claims representative position was not considered by the agency. Kelly claims the SSA’s actions violated his rights under Title VII of the Civil Rights Act (Title VII), 42 U.S.C. §§ 2000e, et seq (Title VII); the Age Discrimination in Employment Act of 1967 (ADEA), 29 U.S.C. §§ 621, et seq.; and the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. §§ 12101, et seq.; and under “42 U.S.C. Chapter 21: Civil Rights.” The SSA filed a motion to dismiss. For the reasons that follow I will grant the motion to dismiss. Background According to his complaint, Plaintiff Jason Kelly was hired by the SSA under its Pathways Recent Graduates Program on September 22, 2010. Kelly was hired as a claims specialist. Kelly alleges that in 2012, he informed

management that he had an anxiety disorder for which he took medication and that certain environmental factors can heighten his anxiety. In 2015 and 2016 Kelly expressed his interest in being promoted to a management position. He

was told by one supervisor that he would not be a good manager and that he needed to concentrate on doing his current job. Kelly alleges that a supervisor and other co-workers would purposely conduct business operations in a manner that was stressful to Kelly. In September 2017, Kelly felt so stressed one day

he had to leave work to go home and informed a “higher level employee” that he was leaving the office. The following day he told his supervisor why he went home the day before. A week later, on October 5, 2017, Kelly’s

supervisor told Kelly that he was going to be suspended for two weeks without pay for going home sick. Kelly states that he “got upset” with the supervisor. The supervisor then withdrew the suspension and fired Kelly. Kelly appealed the decision to the Office Manager who upheld the decision to terminate

Kelly’s employment. Kelly believes that his termination was in violation of his disability rights and the Family Medical Leave Act. Kelly states that in 2017 he contacted an attorney about appealing his termination but decided not to do

2 so. In June 2022, Kelly applied for another Pathways Recent Graduate

Program claims specialist job posted by the SSA which was the same job he held when he was terminated. His application was given the status of “no consideration.” When he inquired about that designation he was told by the

SSA that his application was denied because he was not a recent graduate (within two years) and that is why his application was turned down. Kelly asserts that this is age discrimination. He also asserts that when he was originally hired he had been a graduate for more than two years (unspecified

how long he had been a graduate). He alleges that the real reason he was not hired was based on his age and his “anxiety disorder disability condition.” On September 22, 2022, Kelly filed a charge of discrimination with the

Equal Employment Opportunity Commission (EEOC). He asserted a claims based on disability and age discrimination for: (1) not considered for the claims specialist position because he was not a recent graduate and (2) based on his termination on October 5, 2017. On November 2, 2023, the EEOC issued Kelly

a right to sue letter for his failure to hire claim but rejected his 2017 termination claim as untimely. On December 7, 2023, the EEOC issued a decision on Kelly’s request for reconsideration [ECF # 1-1]. The decision

3 notes that Kelly’s claim for a failure to hire was accepted for review but his claim for his 2017 termination was rejected for “untimely EEO Counselor

contact.” The decision also noted that Kelly failed to appeal the dismissal of his 2017 termination claim with the EEOC . The EEOC issued a decision as to Kelly’s failure to hire claim finding that “no discrimination was established”

and issued Kelly a right to sue letter for his failure to hire claim. On February 10, 2024, Kelly filed the present complaint. He alleges that he was not rehired based on his age and disability under the ADEA and ADA respectively. He also asserted claims under Title VII and “42 U.S.C.

Chapter 21: Civil Rights” but does not assert any protected status in support of those claims. In the complaint filed on the Court’s employment discrimination complaint form, Kelly checked the following Nature of the Case section boxes:

failure to hire; termination of employment; failure to promote; failure to accommodate my disability; terms and conditions of employment differ from similar employees; retaliation; and harassment. In the Nature of the Discrimination section of the form Kelly checked disability and age (birth year

1982). Defendant the SSA filed a motion to dismiss asserting that Kelly’s complaint fails to assert claims for which relief can be granted. Kelly opposes

4 the motion. Legal Standard

In ruling on a motion to dismiss, I must accept as true all factual allegations in the complaint and view them in the light most favorable to Plaintiff. Fed. R. Civ. P. 12(b)(6); Erickson v. Pardus, 551 U.S. 89, 94 (2007). An action fails to state a

claim upon which relief can be granted if it does not plead “enough facts to state a claim to relief that is plausible on its face.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007). A “plaintiff’s obligation to provide the grounds of his entitlement to relief requires more than labels and conclusions, and a formalistic

recitation of elements of a cause of action will not do.” Id. (internal quotations omitted). To survive a motion to dismiss a plaintiff’s factual allegations “must be enough to raise a right to relief above the speculative level.” Id. at 555.

Discussion I initially note that Kelly’s claims regarding any alleged discrimination up to and including his termination in 2017 are not cognizable. To bring a claim under Title VII, the ADEA, or the ADA a plaintiff must first exhaust his

administrative remedies by filing a timely charge of discrimination with the Equal Opportunity Employment Commission. See Parisi v. Boeing Co., 400 F.3d 583, 585 (8th Cir. 2005)(ADEA); Shannon v. Ford Motor Co., 72 F.3d

5 678, 684 (8th Cir. 1996)(Title VII); and Kale v. Aero Simulation, Inc., 139 F.4th 684, 689 (8th Cir. 2025)(ADA). Kelly’s failure to timely exhaust his

administrative remedies for these claims is explicitly noted in his complaint. He alleges that he purposely elected not to pursue any claims related to his employment in and before 2017 and, instead, he sought other employment.

Attached to his complaint is a decision from the EEOC appeals panel noting that on November 2, 2023, the EEOC rejected any claims up through 2017 as untimely.

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Kelly v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kelly-v-omalley-moed-2025.