Linda S. Jacoby v. Food Bank for the Heartland

District Court, D. Nebraska·Decided August 7, 2026·No. 8:25-cv-00650·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEBRASKA

LINDA S. JACOBY,

Plaintiff, 8:25CV650

vs. MEMORANDUM AND ORDER FOOD BANK FOR THE HEARTLAND,

Defendant.

Plaintiff Linda S. Jacoby (“Plaintiff”), a non-prisoner proceeding in forma pauperis, see Filing No. 6, filed a Complaint on November 7, 2025 (the “Complaint”), Filing No. 1. The Court is required to review in forma pauperis complaints to determine whether summary dismissal is appropriate. See 28 U.S.C. § 1915(e). For the reasons that follow, this Court finds that, as pleaded, Plaintiff’s Complaint must be dismissed. However, in lieu of dismissal this Court shall sua sponte grant Plaintiff leave to amend her Complaint in accordance with this Memorandum and Order. I. SUMMARY OF COMPLAINT Plaintiff alleges disability discrimination in violation of the Americans with Disabilities Act1 (the “ADA”) and the Family and Medical Leave Act (the “FMLA”) arising from her employment with Defendant Food Bank for the Heartland between January 13, 2025, and her termination on October 23, 2025. Filing No. 1 at 3-4. In support of her claims Plaintiff states: While the central violations began on or about 01/13/25 and continued through my termination on 10/23/25, it is important to note that I had previously submitted a physician's ADA accommodation letter in 2021 for the same disabilities. In 2021, my employer honored those

1 42 U.S.C. §12101 et seq. accommodations under prior leadership. However, when I renewed my request on 01/13/25 and referenced the prior documentation, the organization failed to engage in the interactive process or provide updated ADA paperwork. Instead, I was steered toward FMLA leave despite having clearly communicated that I did not require extended time off, but rather workplace accommodations. This manipulation ultimately left me unprotected when my medical conditions worsened and led to my termination.

Id. at 5. Plaintiff also attaches her “Charge of Discrimination” filed with the Nebraska Equal Opportunity Commission (the “EEOC Charge”). Id. at 8-14. In the EEOC Charge, she elaborated on her claims as follows: 1. Failure to Accommodate

In January 2025, I disclosed my disabilities and formally requested ADA accommodations. Rather than engaging in the required interactive process, leadership rerouted me to FMLA leave, despite my objections, and made no effort to explore alternative options or modified duties. I was not provided with ADA paperwork, and my outreach was either ignored or redirected inappropriately, an unmistakable violation of the ADA's interactive process requirement.

In April 2025, following medical leave, I submitted a second accommodation request to resume evening work twice weekly to complete time-sensitive deliverables. This request was consistent with my long-established schedule and would not have interfered with my recovery. My request was ignored for days. When I followed up, I was met with vague objections and an outright denial, again without meaningful engagement. These repeated failures reflect bad-faith avoidance of legally mandated processes.

2. Retaliation after Disclosure

Immediately after disclosing my disabilities and reporting a hostile work environment to HR in January 2025, I experienced abrupt and severe changes to my role. I was excluded from key meetings I had previously led or co-facilitated, cut off from system access, excluded from the creation of numerous new reporting structures that were essential to my role, and removed from long-standing cross-departmental work. My responsibilities were stripped and redistributed without explanation despite my being the only person with historical knowledge of those workflows. I was left with vague, diminishing tasks inconsistent with my experience or job title. This abrupt shift in treatment directly followed my protected disclosures.

3. Hostile Work Environment

The appointment of Calib Miller as Vice President in October 2024 ushered in a toxic and exclusionary workplace culture. Calib's behavior included aggression, gaslighting, micromanagement, performative support, and public undermining. He created a climate of fear and instability that escalated further after my disclosures.

I reported his conduct to HR in January 2025, describing the escalating hostility, retaliation, and emotionally unsafe environment. Despite multiple internal complaints from me and other staff, no corrective action was taken. My distress grew so severe that by March 2025, I required medical leave. The harm I experienced was directly tied to the organization's failure to address the hostile environment I reported in good faith.

4. Discriminatory Surveillance and Unequal Scrutiny

After attempting to return to work following medical procedures in April 2025, I was placed under a new supervisor, Tresha Rodgers. Instead of supporting my return, Tresha subjected me to invasive and excessive oversight, including frequent questioning about my schedule, broad email surveillance, forced and unnecessary meetings related to common data requests, and demands to document every request and output. These expectations were not applied to my peers and contradicted Tresha's own stated management style and organizational norms. Her behavior, layered atop the already hostile environment, further suggested that my disability status and prior protected activity were being used to justify unequal scrutiny.

5. HR Breakdown and Confirmed Conflict of Interest

Amber Durr, Vice President of HR, failed to take action on multiple internal complaints about Calib Miller, including mine. While concerns about their personal relationship circulated internally for months, the organization formally confirmed their romantic partnership in its June 2025 newsletter, congratulating them on purchasing a home together. This public acknowledgment of a serious conflict of interest casts doubt on the objectivity and neutrality of HR's handling of complaints involving Calib. It also helps explain Amber's pattern of obstruction and inaction.

As employees continued to report abuse, exclusion, and toxic leadership, HR failed to investigate, initiate accountability measures, or protect staff from retaliation. Multiple colleagues were pushed out or resigned while those responsible faced no consequences.

6. Misuse of Leave and Strategic Retaliation

On April 2, 2025, while I was on medically certified leave, I received a threatening email from HR demanding completion of new training modules (following another employee's official complaint of gender discrimination and hostile work environment) or face discipline. These demands ignored my leave status and added unnecessary pressure during a time of active recovery, especially when I still had a week left to complete these trainings.

In addition, during this same period, Calib Miller attempted to coerce me into completing an extensive, high-stakes data report for the Board of Directors, known internally as the quarterly operations metrics, with just two days' notice. This report is highly complex, requiring significant data gathering, analysis, and coordination across departments. I had completed this report several times in the past with the guidance of now-departed executives, and Calib was fully aware of my role, having been copied on related communications since his start in October 2024.

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Linda S. Jacoby v. Food Bank for the Heartland, (D. Neb. 2026).

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