Smith v. Hammer & Steel, Inc

CourtDistrict Court, E.D. Missouri
DecidedMay 2, 2023
Docket4:22-cv-01128
StatusUnknown

This text of Smith v. Hammer & Steel, Inc (Smith v. Hammer & Steel, Inc) 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
Smith v. Hammer & Steel, Inc, (E.D. Mo. 2023).

Opinion

EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

VALERIE SMITH, ) ) Plaintiff, ) ) v. ) Case No. 4:22-CV-01128-AGF ) HAMMER & STEEL, INC., ) ) Defendant. )

MEMORANDUM AND ORDER This matter is before the Court on Defendant Hammer & Steel, Inc.’s Motion to Dismiss Plaintiff Valerie Smith’s complaint pursuant to Federal Rule 12(b)(6). Doc. No. 9. In Counts I and II, Plaintiff asserts claims of age and disability discrimination in violation of the Age Discrimination in Employment Act (“ADEA”) and Americans with Disabilities Act (“ADA”), respectively. In Count III, Plaintiff alleges violations of the Family Medical Leave Act (“FMLA”). Doc. No. 1. For the reasons set forth below, the motion will be granted. BACKGROUND The following facts are taken from the Complaint. Doc. No. 1. Plaintiff was employed with Defendant as a receptionist from October 3, 2016 to November 20, 2021. During the course of Plaintiff’s employment, her husband developed cancer, which became worse in January of 2020. The cancer substantially limited her husband from performing major life activities, so Plaintiff asked her supervisor about taking unpaid leave to care for him. This request was ultimately denied after conversations between her in part because the Vice President did not believe Defendant was required to grant her

request under the FMLA. Plaintiff continued working for Defendant, but in November of 2020, her husband’s condition further deteriorated. On November 13, 2020, Plaintiff’s husband had a medical emergency which required her to call 911, and she was late to work that morning. When her supervisor observed her crying, she gave Plaintiff the rest of the day

and the following week off of work so that Plaintiff could arrange home care for her husband. Defendant knew that Plaintiff was planning to return to work on November 23, 2020. But on November 20, 2020, Defendant informed her through a phone call with Human Resources that she had been terminated for abandoning her job. Plaintiff was 62 years old at the time of her termination. Of Defendant’s employees, only four were older

than the Plaintiff at the time of her termination. Shortly after, in December of 2020, Defendant sought to fire a 65-year-old worker in its St. Louis shop. Plaintiff contacted an attorney in July of 2021 to speak about her termination and whether she had any claims. During that conversation, the attorney relayed to Plaintiff that she could file a charge under federal law with the Equal Employment Opportunities

Commission (“EEOC”). Upon signing a retainer agreement with the attorney, Plaintiff was told by the attorney that she had one year from the date of her termination to file her EEOC charge. However, the EEOC actually has a 300-day deadline to file a charge. Plaintiff promptly reviewed and signed the draft charges prepared by her attorney. Her attorney filed the EEOC charge on October 12, 2021. The EEOC docketed the charge, 2022. On August 9, 2022, Plaintiff’s attorney notified Plaintiff via telephone that the

charge was filed outside the EEOC’s 300-day deadline, and Plaintiff’s attorney admitted that she had miscalculated the deadline. Plaintiff filed a three count Complaint on October 26, 2022. In Count I, Plaintiff claimed discrimination in violation of the ADEA, alleging Defendant terminated her employment on or about November 20, 2020, based on her age. In Count II, Plaintiff

alleged discrimination in violation of the ADA, claiming Defendant terminated her employment when it had knowledge that Plaintiff’s husband had a disability. In Count III, Plaintiff alleged retaliation and interference under the FMLA because she was terminated after requesting and being granted leave by a supervisor. ARGUMENTS OF THE PARTIES

Defendant seeks dismissal of all three counts against it. Defendant argues that Plaintiff’s ADA and ADEA claims are time-barred by the 300-day filing deadline and thus should be dismissed under FRCP 12(b)(6). With respect to Plaintiff’s FMLA claim, Defendant argues that Plaintiff failed to state a claim because she failed to properly allege that Defendant was an eligible employer under FMLA. Specifically, she failed to allege

that Defendant employed more than 50 people within a 75-mile radius. Doc. No. 9. Plaintiff, in response, argues that the doctrine of equitable tolling should be applied to her ADA and ADEA claims due to her reliance on her attorney’s mistaken belief regarding the EEOC deadline. Further, Plaintiff argues that she has alleged sufficient facts under Rule 12(b)(6) to state a claim upon which relief may be granted for DISCUSSION

To survive a motion to dismiss for failure to state a claim, a plaintiff’s allegations must contain “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) (internal quotations omitted). On a motion to dismiss, the court accepts the plaintiff’s factual allegations as true and draws all reasonable inferences in favor of the nonmoving party. Torti v. Hoag,

868 F.3d 666, 671 (8th Cir. 2017). The complaint will be dismissed only if it is clear that no relief can be granted under any set of facts that could be proven consistent with the allegations. Casino Res. Corp. v. Harrah’s Ent. Inc., 243 F.3d 435, 437 (8th Cir. 2001). However, a complaint will not suffice if it contains mere naked assertions without sufficient factual background. Bell Atlantic v. Twombly, 550 U.S. 544, 557 (2007).

Factual enhancement is necessary to bring allegations in a complaint from mere possibility to the required plausibility standard. Id. Untimeliness under a statute of limitations and failure to exhaust administrative remedies are affirmative defenses that a defendant bears the burden to plead and prove. Jessie v. Potter, 516 F.3d 709, 713 n.2 (8th Cir. 2008); see also Miles v. Bellfontaine

Habilitation Ctr., 481 F.3d 1106, 1107 (8th Cir. 2007). A court may dismiss a claim as precluded by the statute of limitations where the complaint itself establishes that the claim is time-barred. Richardson v. Omaha School District, 957 F.3d 869, 873 (8th Cir. 2020). However, such issues often depend on questions of fact, so courts should hesitate to dismiss a complaint on statute of limitations grounds based solely on the face of the F.3d 364, 368 (8th Cir. 2011).

Counts I and II – Equitable Tolling Defendant seeks to dismiss Counts I and II because Plaintiff filed after the EEOC’s 300-day filing deadline, and thus did not exhaust her administrative remedies as required by statute. In response, Plaintiff asserts that the doctrine of equitable tolling should be applied to her claim, and further that 12(b)(6) motions to dismiss should not be granted

where there are questions of fact as to the exhaustion of administrative remedies. Although courts typically do not consider matters outside the pleadings on a motion to dismiss, a court may consider matters of public record. See Levy v. Ohl, 477 F.3d 988, 991 (8th Cir.

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Smith v. Hammer & Steel, Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-hammer-steel-inc-moed-2023.