Reid v. Shelby County Board of Education

CourtDistrict Court, W.D. Tennessee
DecidedMarch 30, 2020
Docket2:19-cv-02056
StatusUnknown

This text of Reid v. Shelby County Board of Education (Reid v. Shelby County Board of Education) is published on Counsel Stack Legal Research, covering District Court, W.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Reid v. Shelby County Board of Education, (W.D. Tenn. 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TENNESSEE WESTERN DIVISION

A.S., BY HER NEXT FRIEND AND ) MOTHER, JANIELE REID, and ) JANIELE REID, individually, ) ) Plaintiffs, ) ) v. ) Case No.: 2:19-cv-02056-JTF-cgc ) SHELBY CTY. BD. OF ) EDUC. and GREG MCCULLOUGH, in his ) Individual and official capacities, ) ) Defendants. )

ORDER ADOPTING MAGISTRATE JUDGE’S REPORT AND RECOMMENDATION AND GRANTING MOTION FOR JUDGMENT ON THE PLEADINGS

Plaintiffs Reid and A.S. filed their five-count Complaint against the above-named Defendants in this Court on January 22, 2019. (ECF No. 1.) On November 22, 2019, the Defendants filed a Motion for Judgment on the Pleadings As to Plaintiff Janiele Reid’s Individual Retaliation Claim, which is now before the Court. (ECF Nos. 37 & 38.) In it, the Defendants challenge Plaintiff Reid’s (“Plaintiff”) individual claim of retaliation, which is Count V in the Complaint, on the basis that the claim is time-barred and should be dismissed. (ECF No. 38.) The Court referred the Defendant’s Motion for Judgment on the Pleadings to the Magistrate Judge for report and recommendation pursuant to 28 U.S.C. § 636. (ECF No. 39.) The Magistrate Judge entered a Report and Recommendation (“R. & R.”) on January 30, 2020, advocating that the Court grant the Defendants’ Motion and dismiss Plaintiff Reid’s individual claim of retaliation. (ECF No. 74.) Plaintiff filed timely objections to the R. & R. (ECF No. 79), and the Defendants filed a timely response. (ECF No. 85.) For the following reasons the Court finds that the R. & R. should be ADOPTED, and the Defendants’ Motion for Judgment on the Pleadings should be GRANTED. FINDINGS OF FACT

In her R. & R., the Magistrate Judge provides, and this Court adopts and incorporates, proposed findings of fact in this case. (ECF No. 74, 1-3.) LEGAL STANDARD Congress passed 28 U.S.C. § 636(b) “to relieve some of the burden on the federal courts by permitting the assignment of certain district court duties to magistrates.” United States v. Curtis, 237 F.3d 598, 602 (6th Cir. 2001). Pursuant to the provision, magistrate judges may hear and determine any pretrial matter pending before the Court, except various dispositive motions. 28 U.S.C. § 636(b)(1)(A). Regarding those excepted dispositive motions, magistrate judges may still hear and submit to the district court proposed findings of fact and recommendations for disposition. 28 U.S.C. § 636(b)(1)(B). Upon hearing a pending matter, “the magistrate judge

must enter a recommended disposition, including, if appropriate, proposed findings of fact.” Fed. R. Civ. P. 72(b)(1); see also Baker v. Peterson, 67 F. App’x 308, 310 (6th Cir. 2003). Any party who disagrees with a magistrate’s proposed findings and recommendation may file written objections to the report and recommendation. Fed. R. Civ. P. 72(b)(2). The standard of review that is applied by the district court depends on the nature of the matter considered by the magistrate judge. See Baker, 67 F. App’x at 310 (citations omitted) (“A district court normally applies a ‘clearly erroneous or contrary to law’ standard of review for nondispositive preliminary measures. A district court must review dispositive motions under the

2 de novo standard.”). Upon review of the evidence, the district court may accept, reject, or modify the proposed findings or recommendations of the magistrate judge. Brown v. Bd. of Educ., 47 F. Supp. 3d 665, 674 (W.D. Tenn. 2014); see also 28 U.S.C. § 636(b)(1). The court “may also receive further evidence or recommit the matter to the [m]agistrate [j]udge with instructions.”

Moses v. Gardner, No. 2:14-cv-2706-SHL-dkv, 2015 U.S. Dist. LEXIS 29701, at *3 (W.D. Tenn. Mar. 11, 2015). A district judge should adopt the findings and rulings of the magistrate judge to which no specific objection is filed. Brown, 47 F. Supp. 3d at 674. ANALYSIS Defendants raise two primary arguments to support their position that Plaintiff Reid’s individual claim of retaliation, Count V in the Complaint, should be dismissed. (ECF No. 38.) First, Defendants argue that Plaintiff Reid’s individual claim of retaliation, which was originally filed under Tennessee’s Government Tort Liability Act (GTLA), has essentially been re-filed by Plaintiffs as a federal claim, and is now time barred. (ECF No. 38, 4.) The Defendants contend that because the original GTLA retaliation claim is “substantively identical” to the newly filed

federal claim, Tennessee’s savings statute, which does not apply to GTLA claims, should not extend to the same retaliation claim now being brought under federal statutes. (Id.) Plaintiff makes a similar argument that her newly filed retaliation claim arises from the same transaction or occurrence as the allegations in the original complaint, but she reaches an opposite conclusion from the Defendants. Namely, Plaintiff Reid asserts that the Tennessee savings statute should apply because the original claim was not brought under the GTLA. Rather, Plaintiff contends that she merely “referenc[ed]” the GTLA along with other federal statutes and thus, the savings statute

3 was not barred.1 (ECF No. 51, 7-8.) Notwithstanding Plaintiff Reid’s arguments, which the Magistrate Judge addressed separately, the R. &. R. advises this Court not to follow the Defendants’ first argument, concluding that they have offered no authority to support their assertion that Plaintiff Reid’s retaliation claim

under federal law should be construed as a re-filing of her previous state law claim and be time- barred as a result. (ECF No. 74, 5.) Upon review, the Court agrees with this conclusion and therefore adopts the Magistrate Judge’s recommendation to reject the Defendant’s first argument for dismissal. Moreover, adoption of this recommendation is appropriate in the absence of any objection by the parties. Brown, 47 F. Supp. 3d at 674. The Defendants’ second argument for the dismissal of Plaintiff Reid’s federal retaliation claim, is that it is time-barred by the statute of limitations applicable to the ADA, 42 U.S.C. § 12101, et seq, and the Rehabilitation Act, 28 U.S.C. § 794. (ECF No. 38, 5.) Courts seeking to determine the appropriate statute of limitations for federal laws, such as the ADA and Rehabilitation Act, which do not contain a limitations period, should borrow one from the most analogous state cause of action. McCormick v. Miami Univ., 693 F.3d 654, 662 (6th Cir. 2012).2

Here, the R. & R. found that Tennessee’s civil-rights actions, which carry a one-year statute of limitations, are the most analogous state court action to Plaintiffs’ ADA and Rehabilitation Act claims. (ECF No. 74, 5) (citing Williams v. Trevecca Nazarene College, 162 F.3d 1162, n.2 (6th Cir.

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Reid v. Shelby County Board of Education, Counsel Stack Legal Research, https://law.counselstack.com/opinion/reid-v-shelby-county-board-of-education-tnwd-2020.