Marable v. Jack's Family Restaurants

CourtDistrict Court, N.D. Alabama
DecidedJanuary 3, 2024
Docket2:23-cv-00876
StatusUnknown

This text of Marable v. Jack's Family Restaurants (Marable v. Jack's Family Restaurants) is published on Counsel Stack Legal Research, covering District Court, N.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Marable v. Jack's Family Restaurants, (N.D. Ala. 2024).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION

TYLER MARABLE, ) ) Plaintiff, ) ) v. ) Case No. 2:23-cv-00876-NAD ) JACK’S FAMILY ) RESTAURANTS, ) ) Defendant. )

MEMORANDUM OPINION AND ORDER GRANTING DEFENDANT’S MOTION TO DISMISS WITH LEAVE TO AMEND

For the reasons stated below, the court GRANTS Defendant Jack’s Family Restaurants’ motion to dismiss (Doc. 8), and GRANTS Plaintiff Tyler Marable leave to amend his complaint. BACKGROUND A. Procedural background On July 5, 2023, Plaintiff Marable initiated this action by filing a pro se complaint for employment discrimination under the Americans with Disabilities Act of 1990 (ADA). Doc. 1; see 42 U.S.C. § 12112 et seq. The complaint alleges two claims for relief: a discrimination claim related to the termination of Marable’s employment, and a failure to accommodate claim. Doc. 1 at 8–9. On August 31, 2023, Defendant Jack’s filed this motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6), arguing that the complaint fails to state a claim upon which relief can be granted. Doc. 8. Jack’s argues that the complaint

does not include sufficient fact allegations to state a claim for disability discrimination under the ADA, or for a failure to accommodate under the ADA. Doc. 8 at 4–8.

The parties fully briefed the motion to dismiss. Doc. 14 (Marable’s opposition); Doc. 19 (Jack’s reply). The parties consented to magistrate judge jurisdiction. Doc. 16; 28 U.S.C. § 636(c).

B. Allegations in the complaint The complaint alleges that Marable began working at a Jack’s location in November 2020. Doc. 1 at 8. The complaint alleges that Marable has a bipolar

and/or schizoaffective disorder, and that Jack’s discriminated against him based on a “disability or perceived disability.” Doc. 1 at 5. The complaint alleges that, when Marable was hired, he told the hiring manager about his disability. Doc. 1 at 8.

The complaint also alleges that, in January 2021, Marable asked several coworkers if “the Army [was] following [him].” Doc. 1 at 8. The complaint alleges that, a few days later, Marable was informed by his case manager at his group

home that Jack’s had fired him. Doc. 1 at 8. The complaint alleges that Marable then attempted to return to work, but that “[t]he manager . . . locked [him] out of the building.” Doc. 1 at 8.

The complaint alleges further that Marable told his therapist and case manager at his group home that he “was fired for being mentally ill.” Doc. 1 at 9. The complaint alleges that another coworker had argued with Marable’s manager, but

that the coworker had not been fired. Doc. 1 at 9; see Doc. 14 at 2. The complaint alleges that Jack’s “failed to make a reasonable accommodation for [Marable’s] mental illness and fired [him] although [he] was a good worker,” and that he “did not quit as they asserted.” Doc. 1 at 9.

On June 27, 2023, the U.S. Equal Employment Opportunity Commission (EEOC) issued Marable a notice of his right to sue. Doc. 1 at 14–18. Marable did not attach to his complaint a copy of his EEOC discrimination charge.

LEGAL STANDARD Federal Rule of Civil Procedure 8 requires that a complaint must contain “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). Under Federal Rule of Civil Procedure 12(b)(6), the court

can dismiss a complaint for “failure to state a claim upon which relief can be granted.” Id. According to the U.S. Supreme Court, “[d]etailed factual allegations are not

required, but [Rule 8] does call for sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face. A claim has facial plausibility when the pleaded factual content allows the court to draw the reasonable inference that the

defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 663 (2009) (cleaned up) (citing Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007)). “Threadbare recitals of the elements of a cause of action, supported by mere

conclusory statements, do not suffice” to state a plausible claim for relief; and, “[w]hile legal conclusions can provide the complaint’s framework, they must be supported by factual allegations.” Iqbal, 556 U.S. at 663–64, 678 (citations omitted); see Twombly, 550 U.S. at 555 (“[A] plaintiff’s obligation to provide the

grounds of his entitlement to relief requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do.” (cleaned up)). DISCUSSION

I. The complaint does not include sufficient fact allegations to state a plausible claim for relief for disability discrimination under the ADA. Marable’s complaint does not include sufficient fact allegations to state a plausible claim for relief for disability discrimination under the ADA. The ADA prohibits employers from “discriminat[ing] against a qualified individual on the basis of disability in regard to job application procedures, the hiring, advancement,

or discharge of employees, employee compensation, job training, and other terms, conditions and privileges of employment.” 42 U.S.C. § 12112(a). “To state a discrimination claim under the ADA, a plaintiff must allege sufficient facts to plausibly suggest ‘(1) that he suffers from a disability, (2) that he is a qualified individual, and (3) that a “covered entity” discriminated against him

on account of his disability.’” Surtain v. Hamlin Terrace Found., 789 F.3d 1239, 1246 (11th Cir. 2015) (quoting Cramer v. Florida, 117 F.3d 1258, 1264 (11th Cir. 1997)); see also Lucas v. W.W. Grainger, Inc., 257 F.3d 1249, 1255 (11th Cir. 2001)

(similar). The ADA defines “disability” to include any “physical or mental impairment that substantially limits one or more major life activities.” 42 U.S.C. § 12102(1)(A). The ADA Amendments Act of 2008 codifies that “major life

activities” include “concentrating, thinking, communicating, and working.” 42 U.S.C. § 12102(2)(A) (emphasis added). The ADA also defines a “qualified individual” as “an individual who, with or

without reasonable accommodation, can perform the essential functions of the employment position that such individual holds or desires.” 42 U.S.C. § 12111(8); see Beasley v. O’Reilly Auto Parts, 69 F.4th 744, 758–59 (11th Cir. 2023) (same). In this case, the complaint alleges that Marable is an individual with a

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Cramer v. State of Florida
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167 F.3d 1361 (Eleventh Circuit, 1999)
Foman v. Davis
371 U.S. 178 (Supreme Court, 1962)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
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Portia Surtain v. Hamlin Terrace Foundation
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