Langston v. City of Chicago

CourtDistrict Court, N.D. Illinois
DecidedJuly 12, 2023
Docket1:22-cv-05737
StatusUnknown

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

Bluebook
Langston v. City of Chicago, (N.D. Ill. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

LEONARD LANGSTON, SR., ) ) Plaintiff, ) ) vs. ) Case No. 22 C 5737 ) CITY OF CHICAGO, ) ) Defendant. )

MEMORANDUM OPINION AND ORDER

MATTHEW F. KENNELLY, District Judge:

Leonard Langston, Sr., who has been employed by the City of Chicago's Department of Water Management since 2004, has sued the City, alleging that from at least April 2018 to the present, he has been subjected to a hostile work environment and denied overtime opportunities due to his race and national origin. Langston asserts ten claims. Count 1 is a claim for race discrimination under Title VII of the Civil Rights Act of 1964. Count 2 is a parallel claim under the Illinois Human Rights Act. Count 3 is a parallel claim under 42 U.S.C. § 1981, asserted via 42 U.S.C. § 1983. Count 4 is a parallel claim under section 1983 for violation of Langston's constitutional equal protection rights. Count 5 is a parallel claim under the Illinois Civil Rights Act. And Counts 6 through 10 are retaliation claims under these same statutes. The City has filed a motion to dismiss that asserts a host of grounds for dismissal of various claims. The Court will group these a bit differently from the way the City does in its materials. The first set of arguments involve what the Court will categorize as merits issues. First, the City contends that Langston's Monell claims under section 1983 (Counts 3, 4, 9, and 10) are deficient. Second, it contends that his hostile work environment claims (parts of Counts 1, 2, 3, and 4) do not adequately allege an actionable hostile work environment. Third, the City contends that Langston's retaliation

claims (Counts 6, 7, 8, and 9) do not allege retaliation after taking protected action and do not sufficiently allege an actionable adverse action. Fourth, the City asks to strike Langston's request for punitive damages. The City's second set of arguments involve limitations defenses. It contends that Langston's Title VII claims (Counts 1 and 6) are time-barred because Langston did not file them within ninety days of his receipt of a notice of right to sue from the Equal Employment Opportunity Commission. The City also contends that his section 1981 and section 1983 claims (Counts 3, 4, 9, and 10) and his ICRA claims (Counts 5 and 8) are time-barred because he did not file them within two years of accrual of his claims. The third set of arguments involve exhaustion of administrative remedies. The

City argues that Langston's Title VII discrimination claim (Count 1) was not properly exhausted before the EEOC to the extent it involves national origin discrimination and that his IHRA claims (Counts 2 and 7) were not fully exhausted before the relevant state agency. 1. Merits arguments The Court addresses first the City's contentions that certain of Langston's claims are inadequately pleaded and fail to clear the plausibility threshold. First, the discrimination claims adequately allege disparate treatment—relating to overtime opportunities—based on race. But the Court agrees with the City that Langston's current complaint does not adequately allege a claim for a hostile work environment. To state a claim for a racially hostile work environment, a plaintiff must allege that: (1) he was subjected to unwelcome harassment, (2) based on his race, (3) that was so severe or pervasive that it altered the conditions of employment and created

an abusive or hostile work environment, and (4) there is a basis for employer liability. See, e.g., Alamo v. Bliss, 864 F.3d 541, 549 (7th Cir. 2017). Langston's claim, as currently alleged, falls short at least on the third element, as he has alleged only denial of overtime opportunities and a single act of allegedly harassing behavior. The hostile work environment claims embedded in Counts 1 through 4 are dismissed, with leave to amend. Second, on the remaining discrimination claims, Langston has adequately alleged that denial of equal work opportunities based on race was a widespread practice of the City at the Water Department, as required to state a Monell claim against the City under section 1983. There is no heightened pleading standard for Monell

claims, see White v. City of Chicago, 829 F.3d 837, 844 (7th Cir. 2016), and Langston's allegations clear the plausibility threshold. Third, on the retaliation claims, Langston's allegations are arguably somewhat on the thin side. He alleges only that after he filed his EEOC charge, the Water Department "harass[ed] him with passive-aggressive treatment including posing harassing documents at his work station." Am. Compl. ¶ 125. But the standard for actionable retaliation is modest: the alleged adverse employment action need only be something that might dissuade a reasonable worker from engaging in protected activity. See Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53, 68 (2006); Freelain v. Village of Oak Park, 888 F.3d 895, 901-02 (7th Cir. 2018). The Court cannot say, at the motion to dismiss stage, that Langston's allegations are insufficient to clear this threshold. Finally, the Court strikes Langston's punitive damages requests. The City argued

in its motion that punitive damages are unavailable due to its status as a governmental entity. See Def.'s Mot. to Dismiss at 21. Langston did not respond, so he effectively conceded the point. 2. Limitations arguments Next the Court considers the City's limitations-based arguments. The City argues that Langston "received" his notice of right to sue from the EEOC on July 18, 2022 when he downloaded it via a portal on the EEOC's website. He filed this lawsuit, pro se, ninety-one days later, on October 18, 2022. Because the law requires filing of a suit under Title VII within ninety days of receipt of the notice of right to sue, see 42 U.S.C. § 2000e-5(f)(1), the City argues that Langston's Title VII claims are time-barred.

Langston argues, among other things, that the actual receipt date is August 8, 2022, when he received a copy of the notice of right to sue in the mail. He also argues that a limitations defense should not be the basis for dismissal for failure to state a claim. An affirmative defense typically is not an appropriate basis for dismissal for failure to state a claim under Rule 12(b)(6). The main reason is that a plaintiff is not required to anticipate and "plead around" potential affirmative defenses. An affirmative defense may, however, serve as a basis for dismissal under Rule 12(b)(6) if the plaintiff's complaint alleges everything needed to establish that the defense applies as a matter of law, including the absence of a way around the defense. See, e.g., Sidney Hillman Health Ctr. of Rochester v. Abbott Labs., Inc., 782 F.3d 922, 928 (7th Cir. 2015); United States v. Lewis, 411 F.3d 838, 842 (7th Cir. 2005).

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Langston v. City of Chicago, Counsel Stack Legal Research, https://law.counselstack.com/opinion/langston-v-city-of-chicago-ilnd-2023.