Smith v. Pick-N-Pull

CourtDistrict Court, W.D. Washington
DecidedDecember 16, 2020
Docket3:20-cv-06124
StatusUnknown

This text of Smith v. Pick-N-Pull (Smith v. Pick-N-Pull) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Smith v. Pick-N-Pull, (W.D. Wash. 2020).

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 ALISHA SMITH, CASE NO. 3:20-cv-06124-RJB 11 Plaintiff, ORDER TO SHOW CAUSE OR 12 v. AMEND PROPOSED COMPLAINT 13 PICK-N-PULL, et al., 14 Defendants. 15 16 This matter is before the Court on plaintiff’s motion to proceed in forma pauperis (“IFP”) 17 (Dkt. 4) and proposed complaint (Dkt. 1-1), which have been referred to the undersigned by the 18 District Court. See Amended General Order 02-19. 19 Pursuant to 28 U.S.C. § 1915(e)(2), the Court may dismiss a proposed complaint where a 20 plaintiff seeks to proceed IFP and the proposed complaint fails to state a claim or is frivolous or 21 malicious. Here, although plaintiff qualifies financially to proceed IFP, her proposed complaint 22 fails to state a claim upon which relief can be granted, as discussed herein. The Court will 23 provide plaintiff with an opportunity to amend her proposed complaint to correct the deficiencies 24 1 identified in this Order; however, the Court declines to rule on her IFP application until plaintiff 2 has done so. Moreover, failure to timely comply with this Order will result in a recommendation 3 that the matter be dismissed without prejudice. 4 BACKGROUND

5 Plaintiff filed her IFP motion on November 10, 2020 (Dkt. 1) and corrected her motion 6 on December 3, 2020. Dkt. 4. In her proposed complaint, plaintiff seeks to bring claims against 7 six private businesses that formerly employed her: “Pick N Pull” (for employment between 8 December 2019 and March 2020); “Performance Warehouse/NPW” (employment August 2018 9 to December 2019); “O’Reilly Auto Parts” (employment June 2011 to February 2013); 10 “AutoZone” (employment March 2011 to June 2011); and “Fife RV Center” (employment dates 11 unspecified). Dkt. 1-1, at 8–9. 12 Plaintiff appears to base her claims on allegations that in 2013, she was terminated from 13 defendant O’Reilly Auto Parts because of a doctor’s note “even though the doctor’s note stated 14 return to work.” Dkt. 1-1, at 4. Further, in September 2016, she was allegedly fired and called

15 “too sensitive” by a manager at Fife RV Center for informing a manger of a sexually harassing 16 comment that was made to her. Dkt. 1-1, at 4. Plaintiff additionally alleges that she resigned 17 her position at AutoZone in September 2008 after her hours were cut when she made a sexual 18 harassment claim, although she also lists her dates of employment with AutoZone as being 19 during 2011. See Dkt. 1-1, at 4. 20 More recently, plaintiff alleges, she resigned her position at defendant Performance 21 Warehouse in December 2018. Dkt. 1-1, at 4. She appears to allege that she did so because she 22 was subjected to harassment and retaliation. Dkt. 1-1, at 20. And in February 2019, she claims 23

24 1 that she resigned from defendant Pick N Pull due to a severe hostile and unsafe work 2 environment. Dkt. 1-1, at 4. 3 DISCUSSION 4 I. Exhaustion (Title VII claim only)

5 Plaintiff appears to seek to bring claims under Title VII of the Civil Rights Act of 1964 6 (42 U.S.C. § 2000e-3). See Dkt. 1-1, at 4. To bring such a claim in federal court, a plaintiff 7 must first exhaust her administrative remedies. Greenlaw v. Garrett, 59 F.3d 994, 997 (9th Cir. 8 1995); see Khan v. Ace Cab, Inc., No. 2:12-CV-01125-APG, 2013 WL 4046259, at *1 (D. Nev. 9 Aug. 8, 2013) (explaining that plaintiff had to file a charge with the EEOC and bring suit in 10 federal court within 90 days of receiving a right-to-sue letter). 11 Plaintiff attaches a right to sue letter from the EEOC dated August 5, 2020. Dkt. 1-1, at 12 47. The Court is unable to discern whether plaintiff received this letter within 90 days of filing 13 her complaint (see Dkt. 1-1, at 47), so that the Court cannot tell whether it has subject matter 14 jurisdiction over this case. In addition, plaintiff has failed to clearly allege or identify the

15 substance of her complaint to the EEOC or other appropriate agency, so that the Court cannot 16 discern whether plaintiff’s complaint to the EEOC that resulted in the right-to-sue letter 17 exhausted some, all, or none of the allegations that form the basis for her complaint. See Shah v. 18 Mt. Zion Hosp. & Med. Ctr., 642 F.2d 268, 271 (9th Cir. 1981) (“The district court lacked 19 subject matter jurisdiction over these additional claims [to those raised in the EEOC complaint] 20 because [plaintiff] failed to raise them before the EEOC.”). 21 In addition, if plaintiff seeks to bring claims for hostile work environment, sexual 22 harassment, and retaliation under Title VII, plaintiff should amend her complaint to clearly 23 articulate the allegations against each defendant that form the basis for her claims. To make out

24 1 a prima facie case of retaliation under Title VII, plaintiff must clearly and distinctly articulate (1) 2 that she was involved in a protected activity, (2) that she suffered a “materially adverse” action, 3 and (3) a causal link between the two. Brooks v. City of San Mateo, 229 F.3d 917, 928 (9th Cir. 4 2000) (citing Payne v. Norwest Corp., 113 F.3d 1079, 1080 (9th Cir. 1997)); see also Burlington

5 Northern & Santa Fe Rwy. Co. v. White, 458 U.S. 53, 68 (2006) (setting forth the “materially 6 adverse” standard), superseded on other grounds as stated inWellness Int’l Network, Ltd. v. 7 Sharif, 575 U.S. 665 (2015). 8 Regarding the claim of a hostile work environment, plaintiff must show that the 9 harassment suffered was sufficiently severe or pervasive to alter the conditions of employment 10 and create an abusive working environment. See Meritor Sav. Bank, FSB v. Vinson, 477 U.S. 57, 11 67 (1986). Plaintiff should explain if her claim of hostile work environment is based on sexual 12 harassment or some other grounds. 13 II. WPA Claim 14 In addition, plaintiff appears to seek to bring claims under the Whistleblower Protection

15 Act of 1989 (“WPA”), Pub.L. No. 101–12, 103 Stat. 16 (1989) (codified in scattered sections of 16 5 U.S.C.). Dkt. 1-1, at 4. This statute applies to federal employees and not to plaintiff. See, e.g., 17 Bunce v. Computer Scis. Corp., 113 F. Supp. 3d 234, 237 (D.D.C. 2015). Therefore, plaintiff’s 18 claims under the WPA do not appear to be cognizable. 19 III. FLSA Claims 20 The FLSA’s statute of limitations requires actions to be commenced “within two years 21 after the cause of action accrued, except that a cause of action arising out of a willful violation 22 may be commenced within three years after the cause of action accrued.” 29 U.S.C. § 255(a). 23 Here, the bulk of plaintiff’s claims relate to events that allegedly occurred before 2017. See Dkt.

24 1 1-1, at 4. These claims appear to be barred by the FLSA’s statute of limitations and do not 2 appear to be viable. Therefore, the Court focuses on those claims under the FLSA against 3 defendants Pick N Pull and Performance Warehouse. 4 The elements of a claim of retaliation under the FLSA are that an employer “discharge[d]

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Smith v. Pick-N-Pull, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-pick-n-pull-wawd-2020.