Makale Washington v. Sodecia Automotive

CourtCourt of Appeals for the Sixth Circuit
DecidedOctober 21, 2025
Docket25-1362
StatusUnpublished

This text of Makale Washington v. Sodecia Automotive (Makale Washington v. Sodecia Automotive) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Makale Washington v. Sodecia Automotive, (6th Cir. 2025).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 25a0486n.06

No. 25-1362

UNITED STATES COURT OF APPEALS FILED FOR THE SIXTH CIRCUIT Oct 21, 2025 KELLY L. STEPHENS, Clerk ) MAKALE WASHINGTON, ) Plaintiff-Appellant, ) ON APPEAL FROM THE ) UNITED STATES DISTRICT v. ) COURT FOR THE EASTERN ) DISTRICT OF MICHIGAN SODECIA AUTOMOTIVE, ) Defendant-Appellee. ) OPINION )

Before: KETHLEDGE, LARSEN, and BLOOMEKATZ, Circuit Judges.

BLOOMEKATZ, Circuit Judge. After Sodecia Automotive terminated Makale

Washington’s employment, Washington sued Sodecia, alleging that he suffered race

discrimination in violation of Title VII of the Civil Rights Act of 1964 and Michigan’s Elliott-

Larsen Civil Rights Act (ELCRA) and retaliation in violation of Title VII, ELCRA, and 42 U.S.C.

§ 1981. The district court granted Sodecia’s motion to dismiss for failure to state a claim and

denied Washington leave to amend his complaint. We affirm.

BACKGROUND

Because this case comes before us on a motion to dismiss, we recite the facts as they are

alleged in the complaint. Gavitt v. Born, 835 F.3d 623, 639–40 (6th Cir. 2016).

Makale Washington, an African American male, began working for Sodecia Automotive

in January 2023. During the hiring process, Washington underwent three interviews and a

walkthrough, and Plant Manager Harry Peoples told him that he would have “support” and

“longevity” in the job. Compl., R. 1, PageID 2 ¶¶ 8–9. No. 25-1362, Washington v. Sodecia Automotive

On his first workday, Sodecia assigned Washington to the second shift and partnered him

with the first shift supervisor, Carl.1 According to Washington, Carl lacked managerial experience

and knowledge of Washington’s department. When Washington asked questions and requested

tools to complete his job, Carl responded that he had not received any training to assist

Washington.

Washington also observed that employees on the first shift had more tools and support than

those on the second shift. Despite the disparity in tools and support, Sodecia criticized Washington

for not completing his tasks and expected him to work hours beyond his paid shift. Sodecia

allegedly blamed Washington even though the incomplete work was outside of his job description.

Washington repeatedly requested a meeting with Peoples to discuss these issues, but Peoples never

scheduled a meeting despite promising to find time.

The pivotal incident Washington described from his employment at Sodecia occurred after

a tool broke during his shift. As Washington recounts, he requested support by messaging the work

group chat. Another employee, Paulo, told Washington to call for help. In response, Washington

explained to Paulo that calling for help “was not his job” and that he was occupied with his actual

job responsibilities, namely supervising. Id. at PageID 3 ¶ 21. Paulo told Washington not to speak

to him “that way” and to “do his job.” Id. ¶ 22.

One week later, Peoples and a Human Resources employee named Karla met with

Washington to discuss his interaction with Paulo. Paulo did not attend the meeting. Karla

confirmed that Paulo had told Washington to complete tasks outside of his job description. At

Washington’s request, Peoples and Karla agreed to instruct Paulo not to speak disrespectfully to

1 Washington’s complaint, from which we derive the facts, does not provide surnames for most Sodecia employees.

-2- No. 25-1362, Washington v. Sodecia Automotive

Washington. When Washington left the meeting to return to work, another employee, Charles,

stopped him and began yelling at him and pointing in his face.

The next day, Sodecia terminated Washington for “performance reasons.” Id. at PageID 4

¶ 27. Washington described the termination as “unfair” because he had not been properly trained

for his job. Id.

After Washington exhausted his administrative remedies, he filed suit against Sodecia,

alleging race discrimination in violation of Title VII and ELCRA and retaliation in violation of

Title VII, ELCRA, and 42 U.S.C. § 1981. Sodecia moved to dismiss Washington’s complaint for

failure to state a claim. See Fed. R. Civ. P. 12(b)(6). The district court concluded that Washington’s

complaint fell “woefully short” of alleging sufficient facts to plead race discrimination and

retaliation claims under Title VII, ELCRA, and § 1981. Op. & Order, R. 10, PageID 53.

Accordingly, the district court granted Sodecia’s motion and denied Washington’s request for

leave to amend his complaint.

Washington timely appealed.

ANALYSIS

We review de novo the dismissal of a complaint under Rule 12(b)(6). Savel v. MetroHealth

Sys., 96 F.4th 932, 939 (6th Cir. 2024). To avoid dismissal, Washington’s complaint must put forth

“sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’”

Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544,

570 (2007)). Conclusory allegations are not entitled to the assumption of truth. Id. at 679.

Washington must plead facts that allow us to draw the reasonable inference that Sodecia engaged

in the misconduct alleged. Id. at 678. We review the district court’s denial of leave to amend a

-3- No. 25-1362, Washington v. Sodecia Automotive

complaint for abuse of discretion. Evans v. Pearson Enters., Inc., 434 F.3d 839, 853 (6th Cir.

2006).

Applying these standards, we affirm.

I. Race Discrimination Claims

Washington alleges that Sodecia discriminated against him on the basis of race, in violation

of Title VII and ELCRA. Title VII prohibits an employer from discriminating against any

individual “with respect to his compensation, terms, conditions, or privileges of employment”

because of the employee’s race. 42 U.S.C. § 2000e-2(a)(1). ELCRA similarly prohibits an

employer from discriminating against any individual “with respect to employment, compensation,

or a term, condition, or privilege of employment” because of race. Mich. Comp. Laws

§ 37.2202(1)(a). We analyze Title VII and ELCRA claims similarly. See Humenny v. Genex Corp.,

390 F.3d 901, 906 (6th Cir. 2004).

At the motion to dismiss stage, Washington must plead facts that allow the court to draw

the reasonable inference that Sodecia is liable for the misconduct alleged in his Title VII and

ELCRA race discrimination claims. Washington need not plead a prima facie case of race

discrimination under the McDonnell Douglas framework because that case established “an

evidentiary standard, not a pleading requirement.” Swierkiewicz v. Sorema N.A., 534 U.S. 506, 510

(2002); see also Keys v.

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