Mariah Coates v. Chimes/Holcomb Behavioral Health

District Court, E.D. Pennsylvania·Decided October 22, 2025·No. 5:25-cv-05993·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

MARIAH COATES, : Plaintiff, : : v. : CIVIL ACTION NO. 25-CV-5993 : CHIMES/HOLCOMB BEHAVIORAL : HEALTH, : Defendant. :

MEMORANDUM GALLAGHER, J. OCTOBER 22, 2025 Plaintiff Mariah Coates filed a pro se Complaint naming Chimes/Holcomb Behavioral Health as the Defendant and asserting claims under Title VII of the Civil Rights Act of 1964 (“Title VII”). Coates also seeks leave to proceed in forma pauperis and the appointment of counsel. For the following reasons, the Court will grant Coates leave to proceed in forma pauperis, dismiss the Complaint with leave to amend, and deny the motion for counsel as premature. I. FACTUAL ALLEGATIONS Coates’s Complaint consists of the form available to pro se litigants to file employment discrimination claims as well as materials that she submitted to the EEOC.1 By checking boxes on the Complaint form, Coates appears to assert claims based on termination of her employment, a failure to accommodate her Christian religion, and retaliation. (Compl. at 2-3). In the area of the form that asks Coates to state the facts of the case, she only wrote “Please see attached paperwork.” (Id. at 3.) The paperwork includes a Charge of Discrimination she filed with the

1 The Court adopts the pagination supplied to the Complaint by the CM/ECF docketing system. EEOC in which she asserted that her religious beliefs were affected by her employer’s requirement that she use a “facial recognition clock in and clock out” system. (Id. at 5.) She claimed in the paperwork that the employer denied her an unspecified reasonable accommodation and terminated her employment “in retaliation to my request.” (Id.) Also

attached to the Complaint is a form that, while unclear, may have been submitted by Coates to her employer. (Id. at 7.) The form states that Coates “was bombarded on 2/23/2024 by Kim Nace informing that I had to scan my face . . . I informed Kim I did not feel comfortable, she then stated to me ‘I’m trying to get you paid.’ At that point I no longer felt comfortable discussing that matter any further with Kim.” (Id.) Coates seeks injunctive relief and money damages. (Id. at 9.) II. STANDARD OF REVIEW The Court grants Coates leave to proceed in forma pauperis since she appears unable to pay the filing fee. Accordingly, 28 U.S.C. § 1915(e)(2)(B)(ii) requires the Court to dismiss the Complaint if it fails to state a claim. Whether a complaint fails to state a claim under §

1915(e)(2)(B)(ii) is governed by the same standard applicable to motions to dismiss under Federal Rule of Civil Procedure 12(b)(6), see Tourscher v. McCullough, 184 F.3d 236, 240 (3d Cir. 1999), which requires the Court to determine whether the complaint contains “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) (quotations omitted); Talley v. Wetzel, 15 F.4th 275, 286 n.7 (3d Cir. 2021). At this early stage of the litigation, the Court will accept the facts alleged in the Complaint as true, draw all reasonable inferences in the plaintiff’s favor, and ask only whether the Complaint contains facts sufficient to state a plausible claim. Shorter v. United States, 12 F.4th 366, 374 (3d Cir. 2021), abrogation on other grounds recognized by Fisher v. Hollingsworth, 115 F.4th 197 (3d Cir. 2024) (3d Cir. 2024). Conclusory allegations do not suffice. Iqbal, 556 U.S. at 678. The Court construes the allegations of a pro se complaint liberally. Vogt v. Wetzel, 8 F.4th 182, 185 (3d Cir. 2021). However, ‘“pro se litigants still must allege sufficient facts in

their complaints to support a claim.’” Id. (quoting Mala, 704 F.3d at 245). An unrepresented litigant “cannot flout procedural rules — they must abide by the same rules that apply to all other litigants.” Id.; see also Doe v. Allegheny Cnty. Hous. Auth., No. 23-1105, 2024 WL 379959, at *3 (3d Cir. Feb. 1, 2024) (per curiam) (“While a court must liberally construe the allegations and ‘apply the applicable law, irrespective of whether the pro se litigant mentioned it be name,’ Higgins v. Beyer, 293 F.3d 683, 688 (3d Cir. 2002), this does not require the court to act as an advocate to identify any possible claim that the facts alleged could potentially support.”). Moreover, a complaint may be dismissed for failing to comply with Federal Rule of Civil Procedure 8. Garrett v. Wexford Health, 938 F.3d 69, 91 (3d Cir. 2019). To conform to Rule 8, a pleading must contain a short and plain statement showing that the plaintiff is entitled to relief.

See Travaline v. U.S. Supreme Court, 424 F. App’x 78, 79 (3d Cir. 2011) (per curiam) (“Rule 8 of the Federal Rules of Civil Procedure requires that a complaint contain ‘a short and plain statement of the claim showing that the pleader is entitled to relief,’ and ‘a demand for the relief sought.’”) (quoting Fed. R. Civ. P. 8(a)(2), (3)); see also id. (“Each averment must be ‘simple, concise, and direct.’”) (quoting Fed. R. Civ. P. 8(d)(1)). “This standard operates in tandem with that of Rule 10,” which requires that a pleading contain a caption with the Court’s name and the names of the parties, and that claims be listed in numbered paragraphs. Fabian v. St. Mary’s Med. Ctr., 2017 WL 3494219, at *3 (E.D. Pa. Aug. 11, 2017) (citing Fed. R. Civ. P. 10). The United States Court of Appeals for the Third Circuit has explained that in determining whether a pleading meets Rule 8’s “plain” statement requirement, the Court should “ask whether, liberally construed, a pleading ‘identifies discrete defendants and the actions taken by these defendants’ in regard to the plaintiff’s claims.” Garrett, 938 F.3d at 93 (citation

omitted). A pleading may still satisfy the “plain” statement requirement “even if it is vague, repetitious, or contains extraneous information” and “even if it does not include every name, date, and location of the incidents at issue.” Id. at 93-94. The important consideration for the Court is whether, “a pro se complaint’s language . . . presents cognizable legal claims to which a defendant can respond on the merits.” Id. at 94. However, “a pleading that is so ‘vague or ambiguous’ that a defendant cannot reasonably be expected to respond to it will not satisfy Rule 8.” Id. at 93; see also Fabian v. St. Mary’s Med. Ctr., No. 16-4741, 2017 WL 3494219, at *3 (E.D. Pa. Aug.

Free access — add to your briefcase to read the full text and ask questions with AI

Mariah Coates v. Chimes/Holcomb Behavioral Health, (E.D. Pa. 2025).

Mariah Coates v. Chimes/Holcomb Behavioral Health (Mariah Coates v. Chimes/Holcomb Behavioral Health) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Scott Travaline v. US Supreme Ct
424 F. App'x 78 (Third Circuit, 2011)
Salahuddin v. Cuomo
861 F.2d 40 (Second Circuit, 1988)
Little v. Wuerl
929 F.2d 944 (Third Circuit, 1991)
Tabron v. Grace
6 F.3d 147 (Third Circuit, 1993)
Higgins v. Beyer
293 F.3d 683 (Third Circuit, 2002)
Sandra Connelly v. Lane Construction Corp
809 F.3d 780 (Third Circuit, 2016)
Estate of Egenious Coles v. Zucker, Goldberg & Ackerman
658 F. App'x 108 (Third Circuit, 2016)
Kareem Garrett v. Wexford Health
938 F.3d 69 (Third Circuit, 2019)
Steven Vogt v. John Wetzel
8 F.4th 182 (Third Circuit, 2021)
Christopher Shorter v. United States
12 F.4th 366 (Third Circuit, 2021)
Quintez Talley v. John E. Wetzel
15 F.4th 275 (Third Circuit, 2021)
Gerald Groff v. Louis DeJoy
35 F.4th 162 (Third Circuit, 2022)
Tony Fisher v. Jordan Hollingsworth
115 F.4th 197 (Third Circuit, 2024)