Oberlander v. New Castle County

CourtDistrict Court, D. Delaware
DecidedAugust 1, 2025
Docket1:24-cv-00951
StatusUnknown

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

Bluebook
Oberlander v. New Castle County, (D. Del. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE SUSAN OBERLANDER, ) ) Plaintiff, ) ) v. ) C.A. No. 1:24-cv-00951-JLH-SRF ) NEW CASTLE COUNTY, ) MATTHEW MEYER in his individual ) capacity as New Castle County Executive, ) DR. JACQUELINE JENKINS in her ) individual capacity as Human Resources _+) Officer ) Defendants. ) REPORT AND RECOMMENDATION Presently before the court is Defendants’ motion to dismiss Plaintiff, Susan Oberlander’s (“Plaintiff”) First Amended Complaint (“FAC”) (D.I. 5) for failure to state a claim, pursuant to Federal Rule of Civil Procedure 12(b)(6). (D.I. 7)! Plaintiff asserts claims against Defendants, New Castle County (“NCC”), Matthew Meyer (“Meyer”), in his individual capacity as New Castle County Executive and Dr. Jacqueline Jenkins (“Jenkins”), in her individual capacity as Human Resources Officer, (collectively, “Defendants”) for gender discrimination, sexual harassment, and retaliation pursuant to Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e (“Title VII’) and the Delaware Discrimination in Employment Act (““DDEA”). 19 Del. C. § 710, et. seq. Plaintiff alleges that NCC deprived her of equal protection guaranteed by the Fourteenth Amendment and 42 U.S.C. § 1983. For the following reasons, the court recommends Defendants’ motion to dismiss be GRANTED-IN-PART and DENIED-IN-PART.

' The briefing submitted for this motion can be found at D.I. 8, D.I. 9, and D.I. 10.

L BACKGROUND A. Factual Background Plaintiff filed this employment discrimination suit against New Castle County, Office of Assessment, Meyer, in his individual capacity as County Executive, and Jenkins, in her individual capacity as Human Resources Officer. (D.I. 5) Plaintiff alleges that NCC engaged in gender discrimination, fostered a hostile work environment of undeterred sexual harassment and gender discrimination, retaliated against her, engaged in a discriminatory policy, custom, and practice, refused to properly investigate claims of sexual harassment, and failed to adequately supervise and train its employees regarding claims of sexual harassment. (/d.) Plaintiff has been an employee of New Castle County since July 2, 2018, and currently works there as an Assessment Analyst. (D.I. 5 at 73) On January 25, 2021, John Farnan (“Farnan”) was promoted to the position of Property Assessment Services Administrator. (Jd. at 430) At that time, Farnan became the supervisor of ten Certified Assessors, including Plaintiff. The lawsuit arises from two instances, in July and November of 2022, in which Farnan is alleged to have sent the Plaintiff sexually explicit and otherwise inappropriate text messages. The first instance occurred on July 9, 2022. (/d. at {§ 40-41) Thereafter, on July 11, 2022, Farnan contacted Plaintiff via email and asked her to respond to his text messages. Plaintiff responded that she would no longer communicate with him via text message. (/d. at J 43) Approximately four months later, on November 8, 2022, Farnan sent approximately sixty-four (64) sexually explicit and otherwise inappropriate text messages to Plaintiff's work phone. (Jd. at § 44) On November 9, 2022, Plaintiff reported Farnan’s sexual harassment to his supervisor, Denzil Hardman (“Hardman”), who was the New Castle County Accounting and Fiscal Manager. (D.I. 5 at 9 46) Plaintiff subsequently filed a formal complaint as instructed by

NCC’s Human Resources’ representative. (/d. at ]51) Plaintiff contends in this lawsuit that the investigation of her complaint was mishandled and unreasonably delayed. (/d. at ¢53) Plaintiff alleges that her employer eventually substantiated Plaintiff's complaint, but that NCC’s investigation took over four months and only resulted in the demotion of Farnan. (/d. at | 60- 63) Therefore, Farnan regularly came to work for NCC during the investigation and remained in close working proximity to the Plaintiff even after his demotion. (Jd. at | 68-70) As aresult of the harassment, Plaintiff filed a Charge of Discrimination with the Delaware Department of Labor (““DDOL”) and Equal Employment Opportunity Commission (“EEOC”) on May 4, 2023 (Charge No. OBE050523/17C-2023-00321). (D.I. 5 at J 156) On June 30, 2023, Defendant NCC posted an opening for the “Property Assessment Services Administrator” position formerly occupied by Farnan. (/d. at 4] 78-79) Plaintiff applied for a promotion to Property Assessment Services Administrator on July 10, 2023. Plaintiff was interviewed for the position by Hardman, Laura McDermott, Rafat Kille, and an unknown individual from NCC’s Finance Department. (d. at { 81) Plaintiff alleges that she was not offered the position, and learned on September 18, 2023, that it was offered to a less-qualified candidate. □□□ at { 82) Consequently, Plaintiff filed a second Charge of Discrimination with the Delaware Department of Labor and Equal Employment Opportunity Commission on October 23, 2023 (Charge No. OBE102323/17C- 2024-00189), alleging, among other claims, retaliation as demonstrated by the failure to promote her. (id. at J 86) On October 2, 2023, Plaintiff applied for another promotion to the position that opened for an Assessment Analyst. On October 25, 2023, Plaintiff was interviewed for the position and Hardman was, again, on the panel of decision-makers. (D.I. 5 at 90) On November 9, 2023,

Plaintiff learned she was not offered the position and alleges that a lesser qualified candidate was promoted. (/d. at J 91) Plaintiff alleges that she was denied this promotion because of her complaints of discrimination and that Hardman, who was on the hiring board for both of her interviews, was aware of her complaints of harassment, discrimination, and retaliation. (/d. at 996) As a result, Plaintiff filed a third Charge of Discrimination with the Delaware Department of Labor and Equal Employment Opportunity Commission on November 20, 2023 (Charge No. OBE112023 / 17C-2024-00160). (id. at | 98) For Charge No. OBE050523/17C-2023-00321, Plaintiff received a Right to Sue letter from the DDOL on June 25, 2024, and a Right to Sue letter from the EEOC on July 11, 2024. (Id. at § 105) For Charge No. OBE102323/17C-2024-00189, Plaintiff received a Right to Sue letter from the DDOL on August 14, 2024, and a Right to Sue letter from the EEOC on August 26, 2024. (id. at { 106) For Charge No. OBE] 12023/17C-2024-00160, Plaintiff received a Right to Sue letter from the DDOL on May 17, 2024, and a Right to Sue letter from the EEOC on June 17, 2024. (D.I. 5 at { 107) B. Procedural History Plaintiff filed this case on August 15, 2024. (D.I. 1) On August 29, 2024, Defendants filed a motion to dismiss. (D.I. 3) Plaintiff filed the FAC on September 5, 2024, mooting the motion. (D.I. 5) In the FAC, Plaintiff asserts claims against NCC for gender discrimination, sexual harassment, hostile work environment, and retaliation, in violation of Title VII, 42 U.S.C. § 1983 and the Delaware Discrimination in Employment Act, 19 Del. C. § 710 et. seq. (Counts I & II) and asserts Monell claims against all Defendants pursuant to 42 U.S.C. § 1983 and the Equal Protection Clause of the Fourteenth Amendment (Counts ITI & IV). (D.L. 5 at 9] 102-96)

On September 19, 2024, Defendants moved to dismiss Counts I and III for improper “shotgun” pleading and Counts II, III, and IV for failure to state a claim for which relief may be granted. (D.I.

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Bluebook (online)
Oberlander v. New Castle County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/oberlander-v-new-castle-county-ded-2025.