Ramos v. Hog Slat, Inc.

CourtDistrict Court, D. Nebraska
DecidedFebruary 10, 2025
Docket8:23-cv-00081
StatusUnknown

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

Bluebook
Ramos v. Hog Slat, Inc., (D. Neb. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEBRASKA

JONATHAN F. RAMOS,

Plaintiff, 8:23CV81

vs. MEMORANDUM AND ORDER HOG SLAT, INC.,

Defendant.

Plaintiff Jonathan F. Ramos (“Plaintiff”) filed this case on March 3, 2023, and was given leave to proceed in forma pauperis. The Court conducted an initial review of Plaintiff’s Complaint, Filing No. 1, and supplement, Filing No. 6, (collectively the “Complaint”) pursuant to 28 U.S.C. § 1915(e)(2), and entered a Memorandum and Order on December 28, 2023, Filing No. 10, finding that the Complaint failed to state a claim upon which relief may be granted (hereinafter the “Initial Review Order”). The Court, on its own motion, gave Plaintiff leave to file an amended complaint to allege a claim under Title I of the Americans with Disabilities Act (“ADA”), 42 U.S.C. §§ 12111 to 12117; 42 U.S.C. § 12182, upon which relief may be granted against Defendant Hog Slat, Inc. (“Defendant”). Plaintiff filed his Amended Complaint, Filing No. 11, on January 24, 2024. The Court now conducts a review of Plaintiff’s Amended Complaint pursuant to 28 U.S.C. § 1915(e)(2). I. SUMMARY OF AMENDED COMPLAINT As in his original Complaint, Plaintiff asserts employment discrimination claims against Defendant under the ADA for terminating his employment, failing to accommodate his disability, and subjecting him to unequal terms and conditions of employment because he is deaf. Filing No. 11 at 4. Plaintiff again utilized the form Complaint for Employment Discrimination and, in the section provided for Plaintiff to allege the facts of his case, he wrote “add 1 page,” Id., which is a reference to the one- page handwritten attachment to his Amended Complaint, Id. at 7. Liberally construed, Plaintiff appears to intend his Amended Complaint to supplement the allegations in his

Complaint. The Court, thus, will consider the Amended Complaint as supplemental to Plaintiff’s Complaint. See NECivR 15.1(b). When so construed, Plaintiff’s pleadings also assert an ADA claim for retaliation and claims under the Nebraska Fair Employment Practice Act (“NFEPA”), Neb. Rev. Stat. §§ 48-1104 and 48-1107.02. See Filing No. 1 at 3–4. The Court summarized Plaintiff’s Complaint in the Initial Review Order and incorporates that summary here. Filing No. 10 at 1–4. In his Amended Complaint, Plaintiff alleges the following additional facts in support of his claims: [Defendant] Employer has hard to understand my English limited, they provided Spanish interpreter to talk me, I said I’m Deaf, my language ASL [American Sign Language] different [than] English. I gave information Nebraska Deaf Commission Deaf/Hard of hearing. HR Greg reject, force use English.

Filing No. 11 at 7. As Plaintiff explains,

ASL is a complete and complex language distinct from English, with its own vocabulary and rules for grammar and syntax—it is not simply English in hand signals. ASL has no written component. For several reasons, including early language deprivation, many deaf people have a very limited ability to read and write in English.

Id. (quoting Nat’l Ass’n of the Deaf v. Trump, No. 20CV2107, 2020 WL 4452083 (D.D.C. Aug. 3, 2020)).

Plaintiff further alleges Greg in HR, his Supervisor Jennifer, Manager Tony, and Defendant’s Headquarters rejected his request for an ASL interpreter. Id. Liberally construed, Plaintiff alleges he reported a broken and out of order machine, and his Supervisor Jennifer gave him a false, poor performance review apparently due to the machine breakdown. Id. Thereafter, Plaintiff gave two-weeks’ notice of his resignation “due [to] no access” to ASL interpreter services, though “Spanish service provided daily,” but Plaintiff was instead terminated early. Id.; see also Filing No. 1 at 9.

Plaintiff requests the “same” relief as in his Complaint, i.e. monetary damages and appropriate training on deaf culture for Defendant’s employees. Id. at 5; see also Filing No. 1 at 6–7. II. APPLICABLE LEGAL STANDARDS ON INITIAL REVIEW The Court is required to review in forma pauperis complaints to determine whether summary dismissal is appropriate. See 28 U.S.C. § 1915(e). The Court must dismiss a complaint or any portion of it that states a frivolous or malicious claim, that fails to state a claim upon which relief may be granted, or that seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2)(B).

“The essential function of a complaint under the Federal Rules of Civil Procedure is to give the opposing party ‘fair notice of the nature and basis or grounds for a claim, and a general indication of the type of litigation involved.’” Topchian v. JPMorgan Chase Bank, N.A., 760 F.3d 843, 848 (8th Cir. 2014) (quoting Hopkins v. Saunders, 199 F.3d 968, 973 (8th Cir. 1999)). Plaintiffs must set forth enough factual allegations to “nudge[ ] their claims across the line from conceivable to plausible,” or “their complaint must be dismissed.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 569-70 (2007); see also Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (“A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.”). “A pro se complaint must be liberally construed, and pro se litigants are held to a lesser pleading standard than other parties.” Topchian, 760 F.3d at 849 (internal quotation marks and citations omitted). This means that “if the essence of an allegation

is discernible, even though it is not pleaded with legal nicety, then the district court should construe the complaint in a way that permits the layperson’s claim to be considered within the proper legal framework.” Stone v. Harry, 364 F.3d 912, 915 (8th Cir. 2004). However, even pro se complaints are required to allege facts which, if true, state a claim for relief as a matter of law. Martin v. Aubuchon, 623 F.2d 1282, 1286 (8th Cir. 1980). III. DISCUSSION In the Initial Review Order, the Court set out the standards and elements governing Plaintiff’s claims under the ADA and will not repeat that discussion here. See

Filing No. 10 at 5–11. Instead, Plaintiff’s Complaint and Amended Complaint will be evaluated in light of the Court’s prior discussion.

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