Lynette Walley v. Amazon.com Inc

CourtCourt of Appeals for the Third Circuit
DecidedJune 6, 2024
Docket23-2955
StatusUnpublished

This text of Lynette Walley v. Amazon.com Inc (Lynette Walley v. Amazon.com Inc) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lynette Walley v. Amazon.com Inc, (3d Cir. 2024).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ___________

No. 23-2955 ___________

LYNETTE M. WALLEY, Appellant v.

AMAZON.COM, INC. ____________________________________

On Appeal from the United States District Court for the District of Delaware (D.C. Civil Action No. 1-21-cv-01498) District Judge: Honorable Gregory B. Williams ____________________________________

Submitted Pursuant to Third Circuit L.A.R. 34.1(a) May 28, 2024

Before: KRAUSE, MATEY, and CHUNG, Circuit Judges

(Opinion filed: June 6, 2024) _________

OPINION * _________

PER CURIAM

Lynette Walley appeals from an order dismissing her amended complaint against

her former employer, which she identifies as Amazon.com, Inc. We will affirm.

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. I.

Walley filed suit pro se against Amazon alleging that it wrongfully placed her on

leave, prevented her from clocking in, and changed her stock maturity date and her health

benefits. Her only specific claim was that Amazon took these steps in retaliation for her

filing of a Delaware worker’s compensation claim for injuries that she suffered in an

automobile accident. But Walley also checked a box on the civil cover sheet identifying

her suit as arising under the Americans with Disabilities Act (“ADA”), and she alleged

that a doctor previously had cleared her to work with restrictions. She also filed motions

for leave to proceed in forma pauperis (“IFP”) and for appointment of counsel. The

District Court denied her IFP motion, and she paid the filing fee.

Amazon later filed a motion to dismiss the complaint under Fed. R. Civ. P.

12(b)(6). The District Court then denied Walley’s motions for appointment of counsel

and granted Amazon’s motion to dismiss. The District Court read Walley’s complaint to

assert three categories of claims. First, the District Court read it to assert ADA claims of

disability discrimination and failure to accommodate. The District Court dismissed those

claims “for the reasons set forth by Amazon,” which were Walley’s failure to allege that

she was disabled, that she could be reasonably accommodated, or that she could perform

the essential functions of her job with or without accommodation. Second, the District

Court read the complaint to assert an ADA claim of retaliation for filing a worker’s

compensation claim. The District Court dismissed that claim on the ground that filing a

worker’s compensation claim is not a protected activity under the ADA. Third, and

relatedly, the District Court read the complaint to assert a state-law claim of worker’s

2 compensation retaliation under Del. Code, tit. 19, § 2365. The District Court dismissed

that claim as untimely under the statute’s two-year statute of limitations. For these

reasons, the District Court dismissed Walley’s complaint in its entirety, but it gave her

leave to amend her first category of ADA claims.

Walley then filed a one-page amended complaint attaching certain evidence. On

Amazon’s motion, the District Court dismissed the amended complaint without leave to

further amend. Walley appeals, and we have jurisdiction under 28 U.S.C. § 1291.

II.

In her opening brief, Walley does not challenge or even mention the District

Court’s rulings on any of her claims. To the contrary, she asserts that the District Court

did not commit any legal or factual errors. Thus, we agree with Amazon that Walley has

forfeited any challenge to the District Court’s specific reasons for dismissing her claims,

and we will not review them. See In re Wettach, 811 F.3d 99, 115 (3d Cir. 2016). We

liberally construe Walley’s opening brief to raise two other reviewable issues, but they

lack merit.

First, Walley’s references to her lack of legal knowledge and inability to obtain

counsel could be read to challenge the denial of her motions for appointment of counsel.

But the District Court found that Walley, whose IFP application it denied and who paid

the filing fee, was not “unable to afford counsel” as required for appointment of counsel

under 28 U.S.C. § 1915(e)(1). Walley does not contest that finding, and we see no basis

to disturb it. The District Court did not expressly address appointment of counsel under

42 U.S.C. §§ 2000e-5(f)(1), which authorizes appointment of counsel “in such

3 circumstances as the court may deem just” and which applied in this Title I ADA case by

virtue of 42 U.S.C. § 12117(a). But while indigence might not be a prerequisite for

appointment of counsel under that statute as it is under § 1915, see Nelson v. Boeing Co.,

446 F.3d 1118, 1121 (10th Cir. 2006), “the financial means of the plaintiff” remains “one

of several factors guiding the trial judge’s exercise of discretion in appointing counsel”

under § 2000e-5(f)(1), Hicks v. ABT Assocs., Inc., 572 F.2d 960, 969 (3d Cir. 1978)

(citing Caston v. Sears, Roebuck & Co., 556 F.2d 1305, 1309 (5th Cir. 1977)). Given

that factor and several others, 1 we cannot say that the District Court was required to

appoint counsel in this case.

Second, Walley asserts that “I do not believe that I was given adequate assistance

as a pro se plaintiff.” But courts generally need not provide legal assistance to pro se

litigants, see Mala v. Crown Bay Marina, Inc., 704 F.3d 239, 243-45 (3d Cir. 2013), and

Walley largely fails to explain what she believes the District Court should have done

differently here. She suggests that the District Court improperly dismissed her

complaints for failing to cite statutes and case law, but the District Court did not dismiss

any of her claims for that reason. Instead, the District Court liberally and properly

construed her complaints to raise claims even though she did not mention their legal basis

1 Other factors include the merits of the plaintiff’s claim and her efforts to obtain counsel on her own. See Ficken v. Alvarez, 146 F.3d 978, 979-80 (D.C. Cir. 1998); Caston, 556 F.2d at 1309. Walley’s filings provide no indication that her claims had potential merit. And although she now asserts that she sought counsel but “no one would take the case,” she asserted in the District Court that she was previously represented in connection with these matter by two lawyers, one of whom she fired because she thought he was working in Amazon’s interests and the other of whom declined to continue representing her after she rejected a settlement offer.

4 by name. See id. at 244.

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Related

Nelson v. Boeing Commercial
446 F.3d 1118 (Tenth Circuit, 2006)
Ficken, Ivan v. Alvarez, Aida
146 F.3d 978 (D.C. Circuit, 1998)
Kelley Mala v. Crown Bay Marina
704 F.3d 239 (Third Circuit, 2013)
In re: Thomas C. Wettach v.
811 F.3d 99 (Third Circuit, 2016)
Nicole Haberle v. Borough of Nazareth
936 F.3d 138 (Third Circuit, 2019)

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Lynette Walley v. Amazon.com Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lynette-walley-v-amazoncom-inc-ca3-2024.