Lakeesha Dixon-Starnes v. TikTok U.S. Data Security, Inc., et al.

District Court, M.D. Tennessee·Decided July 20, 2026·No. 3:26-cv-00891·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION

LAKEESHA DIXON-STARNES, ) ) Plaintiff, ) ) v. ) NO. 3:26-cv-00891 ) TIKTOK U.S. DATA SECURITY, INC., ) JUDGE CAMPBELL et al., ) ) Defendants. )

MEMORANDUM OPINION AND ORDER On June 26, 2026, Plaintiff Lakeesha Dixon-Starnes, a Tennessee resident proceeding pro se, filed a Verified Complaint for Injunctive and Monetary Relief (Doc. No. 1, “the Complaint”) against Defendants TikTok U.S. Data Security, Inc., TikTok USDS Joint Venture, LLC, and Bytedance, Inc., asserting claims under the Family and Medical Leave Act of 1993 (FMLA), 29 U.S.C. § 2601 et seq. Plaintiff has now filed an application for leave to proceed in forma pauperis (IFP) (Doc. No. 18) that bears a handwritten signature, as well as a Corrected Emergency Motion for Temporary Restraining Order and Preliminary Injunction (Doc. No. 19) that is personally signed. Plaintiff’s IFP application demonstrates that she cannot afford to pay the $405 filing fee without undue hardship and is therefore GRANTED. 28 U.S.C. § 1915(a). Her motion seeking leave to use a “personally applied handwritten mark” in lieu of “a conventional full signature” (Doc. No. 21-2) is also GRANTED. The Court now proceeds to an initial review of Plaintiff’s filings. I. INITIAL REVIEW Under the pauper statute, the Court must review and dismiss the Complaint if it is frivolous, malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief against a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2)(B); see also Ongori v. Hawkins, No. 16-2781, 2017 WL 6759020, at *1 (6th Cir. Nov. 15, 2017) (“[N]on-prisoners

proceeding in forma pauperis are still subject to the screening requirements of § 1915(e).”). In the course of this initial review, the Court takes up Plaintiff’s Emergency Motion for Temporary Restraining Order and Preliminary Injunction (Doc. No. 19). “Temporary restraining orders and preliminary injunctions are extraordinary remedies which should be granted only if the movant carries h[er] burden of proving that the circumstances clearly demand it.” Ciavone v. McKee, No. 1:08-cv-771, 2009 WL 2096281, at *1 (W.D. Mich. July 10, 2009) (citing Overstreet v. Lexington-Fayette Urban Cnty. Gov’t, 305 F.3d 566, 573 (6th Cir. 2002)). In determining whether to issue a TRO or preliminary injunction, the Court weighs the following four factors: (1) the movant’s likelihood of success on the merits; (2) whether the

movant will suffer irreparable harm without the injunction; (3) whether granting the injunction will cause substantial harm to others; and (4) the impact of the injunction on the public interest. E.g., A&W X-Press, Inc. v. FCA US, LLC, No. 21-1805, 2022 WL 2759872, at *3 (6th Cir. July 14, 2022) (citing Ne. Ohio Coal. for Homeless & Serv. Emps. Int’l Union, Local 1199 v. Blackwell, 467 F.3d 999, 1009 (6th Cir. 2006)). “These four considerations are ‘factors to be balanced, not prerequisites that must be met.’” Id. (quoting Certified Restoration Dry Cleaning Network, LLC v. Tenke Corp., 511 F.3d 535, 542 (6th Cir. 2007)). “[T]he key premise of a preliminary injunction [is] a showing of a likelihood of success on the merits.” L. W. by & through Williams v. Skrmetti, 83 F.4th 460, 471 (6th Cir. 2023), aff’d sub nom. United States v. Skrmetti, 605 U.S. 495 (2025). In this case, the Court cannot find that Plaintiff is likely to succeed on the merits of her claims under the FMLA, because the allegations of her Complaint cast doubt on whether jurisdiction over those claims can be established. “The FMLA allows ‘eligible’ employees up to twelve weeks of unpaid leave during any twelve-month period if the employee meets certain requirements under the Act and has

experienced a triggering event such as the birth of a child, or a ‘serious health condition that makes the employee unable to perform the functions of the position of such employee.’” Cross v. Dental Assisting Acad. of Louisville, LLC, 417 F. Supp. 3d 836, 839 (W.D. Ky. 2019) (quoting 29 U.S.C. § 2612(a)(1)(D)). Plaintiff claims that she suffers from a serious mental health condition and that Defendants both interfered with her exercise of rights under the FMLA, 29 U.S.C. § 2615(a)(1), and retaliated against her for exercising those rights, id. § 2615(a)(2). (Doc. No. 1 at 5–6.) To have any chance of succeeding on her claims, Plaintiff must first establish that she is an “eligible employee” under the FMLA. See Humenny v. Genex Corp., 390 F.3d 901, 906 (6th Cir. 2004) (finding “that the FMLA’s ‘eligible employee’ requirement applies in all FMLA cases,

including retaliation cases”). An “eligible employee” is “an employee who has been employed-- (i) for at least 12 months by the employer with respect to whom leave is requested under section 2612 of this title; and (ii) for at least 1,250 hours of service with such employer during the previous 12-month period.” 29 U.S.C. § 2611(2)(A). “Where a plaintiff does not qualify as an ‘eligible employee,’ the court lacks jurisdiction to decide the FMLA case.” Humenny, 390 F.3d at 904 (citing Douglas v. E.G. Baldwin & Assocs., Inc., 150 F.3d 604, 607 (6th Cir. 1998)). The eligibility requirements of 12 months’ employment and 1,250 service hours are to be measured “as of the date the FMLA leave is to start,” 29 C.F.R. § 825.110(d), “not the day the employer takes an adverse action against the employee.” Ricco v. Potter, 377 F.3d 599, 604 n.4 (6th Cir. 2004); see also Cross, 417 F. Supp. 3d at 840–44 (citing, e.g., Davis v. Mich. Bell Tel. Co., 543 F.3d 345, 350 (6th Cir. 2008) and Butler v. Owens-Brockway Plastic Prods., 199 F.3d 314, 316 (6th Cir. 1999)). “To determine ‘hours of service,’ the FMLA instructs that the legal standards employed by the Fair Labor Standards Act (FLSA), 29 U.S.C. § 207, shall apply. Id. § 2611(2)(C). Under the FLSA, hours of service include only those hours that an employee actually

works; time off for vacation, holiday, or illness is excluded. Id. § 207(e)(2).” Ingrassia v. Cnty.

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Lakeesha Dixon-Starnes v. TikTok U.S. Data Security, Inc., et al., (M.D. Tenn. 2026).

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