Shen v. AAA MO

CourtDistrict Court, E.D. Missouri
DecidedFebruary 5, 2021
Docket4:20-cv-00626
StatusUnknown

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

Bluebook
Shen v. AAA MO, (E.D. Mo. 2021).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

WEIMIN SHEN, ) ) Plaintiff, ) ) v. ) Case No. 4:20-CV-626-SNLJ ) AUTOMOBILE CLUB OF MISSOURI, ) INC., and WILLIAM WOLFF, ) ) ) Defendants. )

MEMORANDUM AND ORDER

Plaintiff Weimin Shen brought this pro se employment discrimination lawsuit against her former employer, defendant Automobile Club of Missouri, Inc., and William Wolff, under Title VII of the Civil Rights Act of 1964. 42 U.S.C. § 2000e, et seq. This matter is before the Court on defendants’ motion to dismiss [#17]. Plaintiff filed a memorandum in response, defendant filed a reply, and plaintiff filed a surreply. Plaintiff has also moved for an extension of time in which to file an audio recording [#25]. I. Factual Background For the purposes of this motion to dismiss, the facts alleged in the complaint are presumed true. In March 2010, plaintiff began working for the defendant, apparently in the IT department. She alleges she was promised certain raises and promotions in order to make her pay commensurate with a male employee, but she says she never received pay on par with that of her male coworkers. She says she complained to defendant’s human resources department and others about the discrepancy beginning in 2011. Plaintiff further alleges that, despite her excellent work and reputation, she received complaints from management about her performance even though similarly-situated male employees with higher salaries were not reprimanded. She also states that defendant

Wolff falsely accused her of not working for several hours in an attempt to force her to quit. In addition, she was given arbitrary deadlines and other requirements that were not required of similarly situated men. She alleges she was terminated on February 8, 2018 due to a fabricated performance issue. She received no raises or bonuses from 2016 until her termination in 2018.

Plaintiff filed her charge of discrimination with the EEOC on July 6, 2018. She named ACMO as the respondent. The EEOC issued its right to sue letter to plaintiff on February 10, 2020. Plaintiff filed this complaint against ACMO and William Wolff on May 8, 2020. Defendants have moved to dismiss the complaint in its entirety, or, in the

alternative, for a more definite statement. II. Motion to Dismiss The purpose of a Rule 12(b)(6) motion to dismiss is to test the legal sufficiency of a complaint so as to eliminate those actions “which are fatally flawed in their legal premises and designed to fail, thereby sparing litigants the burden of unnecessary pretrial

and trial activity.” Young v. City of St. Charles, 244 F.3d 623, 627 (8th Cir. 2001) (quoting Neitzke v. Williams, 490 U.S. 319, 326-27 (1989)). In addressing a motion to dismiss, a court must view the allegations of the complaint in the light most favorable to the plaintiff. United States ex rel. Ambrosecchia v. Paddock Laboratories, LLC., 855 F.3d 949, 954 (8th Cir. 2017). A complaint must be dismissed for failure to state a claim upon which relief can be granted if it does not plead “enough facts to state a claim to

relief that is plausible on its face.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007) (abrogating the prior “no set of facts” standard set forth in Conley v. Gibson, 355 U.S. 41, 45-46 (1957)). Courts “do not require heightened fact pleading of specifics, but only enough facts to state a claim to relief that is plausible on its face.” Id. at 555. A complaint must set forth factual allegations which are enough to “raise a right to relief

above the speculative level.” Id. at 555. However, where a court can infer from those factual allegations no more than a “mere possibility of misconduct,” the complaint must be dismissed. Cole v. Homier Distributing Co., Inc., 599 F.3d 856, 861 (8th Cir. 2010) (citing Ashcroft v. Iqbal, 556 U.S. 662 (2009)). Plaintiff appears to bring claims for sex discrimination in that she earned less

money than similarly situated male coworkers. She also appears to bring a claim for retaliation in that she alleges she was treated differently after she complained about her salary being lower than the salaries of male coworkers. A. Defendant William Wolff First, defendants argue that defendant Wolff should be dismissed because he is not

an employer under Title VII. Title VII makes it an “unlawful employment practice for an employer” to discriminate with respect to compensation, terms, conditions, or privileges of employment. 42 U.S.C. § 2000e-2. Individuals who are not plaintiff’s employer are not covered by Title VII and cannot be liable under it. Schoffstall v. Henderson, 223 F.3d 818, 821 n. 2 (8th Cir. 2000). Defendant Wolff will thus be dismissed. B. Defendant ACOM

Defendant ACOM argues that plaintiff’s claims against it are untimely, vague, conclusory, and are otherwise insufficient to make plausible her claim of sex discrimination and retaliation under Title VII. Title VII requires that plaintiff file a charge of discrimination with the EEOC within 300 days of the discriminatory or retaliative act. 42 U.S.C. § 2000e–5(e); Tademe

v. Saint Cloud State Univ., 328 F.3d 982, 987 (8th Cir. 2003). “Under the continuing violation doctrine, a plaintiff may challenge incidents which occurred outside the statute of limitations period if the various acts of discrimination constitute a continuing pattern of discrimination.” Id. (internal quotation and alterations omitted). “However, discrete acts such as termination, failure to promote, denial of transfer, or refusal to hire are not

actionable if time barred, even when they are related to acts alleged in timely filed charges.” Id. (quoting Nat'l R.R. Passenger Corp. v. Morgan, 536 U.S. 101, 114 (2002)) (internal quotations and alterations omitted). Here, plaintiff filed her EEOC charge on July 6, 2018, thus any acts after September 8, 2017 were within the 300-day limitations period. Plaintiff makes numerous

allegations that end outside of her 300-day window. The first 11 paragraphs of her complaint narrative thus appear to be time-barred as discrete acts. Retaliation, pay, and disparate discipline claims occurring in that pre-September 8, 2017 time frame are discrete acts deemed to occur on the day they happened. See Mems v. City of St. Paul, Dep't of Fire & Safety Servs., 327 F.3d 771, 785 (8th Cir. 2003). Defendant argues that the remaining events, beginning at paragraph 12 of

plaintiff’s complaint narrative, are not specific enough to describe a plausible claim of gender discrimination.

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Shen v. AAA MO, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shen-v-aaa-mo-moed-2021.