Mitchell v. Amazon Corporation

CourtDistrict Court, D. Kansas
DecidedFebruary 28, 2025
Docket2:24-cv-02363
StatusUnknown

This text of Mitchell v. Amazon Corporation (Mitchell v. Amazon Corporation) is published on Counsel Stack Legal Research, covering District Court, D. Kansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mitchell v. Amazon Corporation, (D. Kan. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

BLONDELL F. MITCHELL,

Plaintiff,

v. Case No. 2:24-cv-02363-HLT-ADM

AMAZON CORPORATION AND AMAZON WEB SERVICES,

Defendants.

MEMORANDUM AND ORDER Plaintiff Blondell Mitchell1 brings this case against her former employer, Amazon.com Services LLC2 (“Amazon”) and Amazon Web Services (“AWS”). She brings federal claims alleging that Amazon perceived her as disabled and discriminated against her in violation of the Americans with Disabilities Act (“ADA”).3 Specifically, she claims that Amazon subjected her to discriminatory treatment and a hostile work environment, failed to promote her, and terminated her employment because it believed that she was a drug-addicted prostitute with HIV/AIDS. She also claims under state law that Amazon or AWS published defamatory statements about her and that Amazon wrongfully terminated her employment. Plaintiff seeks more than $6 billion in damages.

1 Plaintiff proceeds pro se. The Court liberally construes Plaintiff’s pro se filings and holds them to a less stringent standard than those drafted by lawyers. See Hall v. Bellmon, 935 F.2d 1106, 1110 (10th Cir. 1991). But the Court does not assume the role of advocate. Id. 2 Defendants represent that Plaintiff incorrectly identified Amazon.com Services LLC in her complaint as Amazon Corp., which is not a legal entity. 3 The governing law is now the ADA Amendments Act of 2008 (“ADAAA”). The Court applies the amended law and regulations. But the Court continues to use the term “ADA” for ease of reference. Defendants move to dismiss. Doc. 9. They contend that none of Plaintiff’s claims are viable. The Court agrees that Plaintiff fails to plausibly state any federal claim. All her federal claims suffer from one overarching problem: Plaintiff fails to plausibly allege facts suggesting that Amazon took any particular action because of Plaintiff’s perceived disability. And Plaintiff only asserts federal-question jurisdiction. The Court declines to exercise supplemental jurisdiction over

Plaintiff’s state-law claims. The Court therefore dismisses Plaintiff’s federal claims with prejudice and her state-law claims without prejudice. I. BACKGROUND Plaintiff worked for Amazon as a “picker.” She claims that Amazon incorrectly believed that she was a drug-addicted prostitute who had HIV/AIDS. Plaintiff claims that Amazon discriminated against her because of this belief. She alleges that Amazon’s managers “tried” to write her up and “tried” to give her a bad review. She also alleges that Amazon assigned her to a broken workstation, assigned her to packing instead of picking, and terminated her employment. Plaintiff alleges that she applied for over fifty positions with the company. But Amazon

never interviewed or selected her for these positions. Plaintiff claims that Amazon employees and managers harassed her because they believed that she was a drug-addicted prostitute with HIV/AIDS. Plaintiff asserts the following events were instances of harassment:4 • An African woman harassed Plaintiff. Plaintiff complained to HR, but HR took no action. A Somali woman or women also harassed her.

• Other employees moved Plaintiff’s nametag so she could not find her workstation. Then managers yelled at her for being at the wrong workstation.

4 Plaintiff identifies additional instances in her response brief and attachment. See, e.g., Doc, 15-1 at 1-3. But Plaintiff cannot amend the allegations in her complaint by adding them in a response to a motion to dismiss. Even if included, however, these allegations do not change the outcome. The Court addresses a few of these instances as examples throughout this order. • Mattie (who was either a supervisor/manager or a coworker) intentionally assigned Plaintiff to broken workstations and moved Plaintiff to a different department if Plaintiff moved to another workstation.

• Other employees acted “smart” with Plaintiff when she made certain comments. One said “the fans are not there to cool you off” when Plaintiff complained about the smell from a broken sardines case.

• Other employees told Plaintiff that “nobody likes her so [she should] quit and kill herself.”

• A manager called Plaintiff “ugly.”

• As noted above, a manager “tried” to write her up and “tried” to give her a bad review. Another manager yelled at her for something that was not her fault.

Plaintiff also claims that Amazon or AWS published false statements about her (including that she was a drug-addicted prostitute with HIV/AIDS, she abandoned her children, and two of her children were not her husband’s children) when it used AWS HR software to “put this on her employment record” and “den[ied] her application/resume within minutes if not seconds.” Doc. 1 at 8. Amazon markets and sells its AWS HR software to the public, and the false information was published to anyone who queried her name. Amazon terminated Plaintiff’s employment on July 14, 2023. Amazon told Plaintiff that she was terminated because she used the wrong pronoun when referring to Mattie (the supervisor/manager or coworker), she had gotten “smart with Mattie” and talked about Mattie behind Mattie’s back, and she stated during a meeting that “foreigners needed to learn how to speak English” and that she “was going to file a complaint with ICE.” Id. at 15. But Plaintiff believes the real reason she was terminated was because she was going to sue Amazon and contact OSHA and AARP. II. STANDARD A complaint survives a Rule 12(b)(6) motion to dismiss when it 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) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). A claim is plausible if it contains sufficient factual content to allow a court “to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. The plausibility standard requires “more than a sheer possibility that a defendant has acted unlawfully,” but it “is not akin to a ‘probability requirement.’” Id. “Where a complaint pleads facts that are merely consistent with

a defendant’s liability, it stops short of the line between possibility and plausibility of entitlement to relief.” Id. (quoting Twombly, 550 U.S. at 557) (internal quotations omitted). A court undertaking this analysis accepts as true all well-pleaded allegations in the complaint but need not accept legal conclusions. Id. Likewise, conclusory statements are not entitled to the presumption of truth. Id. at 678-79. III. ANALYSIS The Court first looks at whether Plaintiff plausibly states a federal claim. She does not. The Court then evaluates whether to exercise supplemental jurisdiction over Plaintiff’s state law claims. Supplemental jurisdiction is not warranted under the circumstances of this case.

A. Federal Claims. 1. ADA Discrimination Claims (Counts I and III). Plaintiff claims that Amazon discriminated against her because it regarded her has having a disability.5 The ADA prohibits covered employers from discriminating against “a qualified individual on the basis of disability in regard to . . . terms, conditions, and privileges of employment.” 42 U.S.C. § 12112(a). A prima facie case of ADA disability discrimination requires the plaintiff to show: (1) she either is disabled or perceived as disabled under the ADA; (2) she is

5 Plaintiff also lists Title VII as a basis for Count I.

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