Stewart v. Wayne County Probate Court

CourtDistrict Court, E.D. Michigan
DecidedFebruary 10, 2025
Docket2:23-cv-12296
StatusUnknown

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

Bluebook
Stewart v. Wayne County Probate Court, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

BRIDGET STEWART, Civil Action No. 23-12296 Plaintiff, Susan K. DeClercq v. United States District Judge

WAYNE COUNTY PROBATE David R. Grand COURT, et al., United States Magistrate Judge

Defendants. _________________________________/

REPORT AND RECOMMENDATION ON DEFENDANTS’ MOTION TO DISMISS (ECF No. 39) The plaintiff in this case, Bridget Stewart (“Stewart”), has worked for defendant Wayne County Probate Court (“WCPC”) for many years. She remains employed there, but, on September 8, 2023, she instituted the present action against the WCPC1 and certain

1 In their motion, Defendants assert that in her initial complaint, Stewart improperly named Wayne County Probate Court as a defendant because “[a] Probate Court is immunized from suit because it is not itself a legal entity capable of being sued.” (ECF No. 39, PageID.284) (citing Bridges v. Senger, 730 F. Supp. 1401, 1408 (6th Cir. 1990). The Court need not resolve that issue because, in her amended complaint, Stewart named Wayne County as a defendant in place of the WCPC. (ECF No. 37). Defendants’ only argument for dismissal of Wayne County is that any claims against Wayne County should be dismissed because, under Fed. R. Civ. P. 25, “a motion is required for a Plaintiff to substitute parties within a case.” (ECF No. 39, PageID.284). That argument lacks merit. First, Rule 25 is inapplicable here because it applies only in certain situations, such as where “a party dies” or “becomes incompetent,” or where “an interest is transferred” that affects the claims in a case. Fed. R. Civ. P. 25. Second, the Federal Rules of Civil Procedure specifically contemplate adding new parties through an amended complaint, as Stewart has done here. Fed. R. Civ. P. 15(c)(1)(C). Accordingly, Defendants’ motion to dismiss should be denied without prejudice as to defendant Wayne County.

The Court does note, however, that serious questions exist as to Wayne County’s propriety as a defendant. See e.g., Est. of Housey ex rel. Housey v. Macomb Cnty., No. 10-11445, 2012 WL 1694629, at *9 (E.D. Mich. May 15, 2012), aff'd sub nom. Housey v. Macomb Cnty., 534 F. App'x of its employees (collectively “Defendants”) claiming that she was wrongfully demoted (or not promoted), and paid less than certain of her colleagues based on her race and age. Thus, Stewart asserts claims under Title VII of the Civil Rights Act of 1964, 42 U.S.C. §

2000e et seq., and the Age Discrimination in Employment Act of 1967 (“ADEA”), 29 U.S.C. § 621 et seq. She also asserts claims for harassment, bullying, and retaliation. Presently before the Court is Defendants’ motion to dismiss (ECF No. 39), which

316 (6th Cir. 2013) (“Macomb County is a party to this case under the theory that it was [Macomb County Probate Court register] Housey's employer. Despite the operational overlap between the court and county, Macomb was not Housey's employer. Circuit and district courts in Michigan receive their funding from the locality they serve. Although ostensibly separate, in practice, counties and cities compliment and supplement the operation of the courts in their jurisdiction. . . . The overlap and integration of operations might give the appearance that Macomb County employed Housey; it did not. The Michigan Supreme Court squarely addressed whether or not a county may employ court personnel in its jurisdiction. The Michigan Supreme Court stated that despite the unique relationship between a court and its funding unit, the judiciary was the employer of court personnel, not the county.”); Pucci v. Nineteenth Dist. Ct., 628 F.3d 752, 763 (6th Cir. 2010) (“Consequently, just as the Michigan Supreme Court is an arm of the state, so is its Nineteenth District Court”); Stewart v. Cnty. of Saginaw, 736 F. Supp. 3d 527, 546 n7 (E.D. Mich. 2024). But see, Turppa v. Cnty. of Montmorency, 710 F. Supp. 2d 619, 621 (E.D. Mich. 2010) (“Several courts have previously considered whether the Michigan trial courts' administrative employees work for the court or the county. Each of those courts have held that an employee of a Michigan state court, whether a probate, circuit, or district court, is an employee of the court and not an employee of the county where the court is located. However, those decisions are not binding authority and do not foreclose consideration of the specific issues and factual circumstances presented in this case. Defendant may be, as Plaintiff contends, her “employer” within the meaning of the ADEA and ELCRA. On the other hand, the Montmorency County Probate Court or the State of Michigan could be her “employers” too. There is simply insufficient information in the record to make that determination at this time.”); Stewart v. Cnty. of Saginaw, 736 F. Supp. 3d 527, 549 (E.D. Mich. 2024) (“In sum, despite Michigan Supreme Court precedent that the state legislature cannot classify state court staff as employees of the county or city the court is located in, such municipalities, in certain factual circumstances, may properly be considered a ‘co- employer’ of a plaintiff pursuing employment discrimination claims.”). Any dispositive motion filed by Wayne County shall thoroughly address these issues. has been fully briefed (ECF Nos. 45, 46, 48).2 The Court finds that oral argument will not aid it in resolving the motion, and declines to hold a hearing. See E.D. Mich. LR 7.1(f)(2).

I. RECOMMENDATION For the reasons set forth below, IT IS RECOMMENDED that Defendants’ Motion to Dismiss (ECF No. 39) be GRANTED IN PART AND DENIED IN PART. II. REPORT A. Background3

Stewart, a sixty-year-old African American woman, began her employment with the WCPC in 2004. (ECF No. 1, PageID.4). In January 2019, Stewart was promoted to the position of a Training Coordinator in the WCPC’s Human Resources (“HR”) Department, and was promoted again to the position of HR Assistant in October 2019. (Id., PageID.5). From this point on, however, Stewart alleges that Defendants engaged in a series of

discriminatory employment practices based on her race, color, and age. For instance, Stewart raises discrimination claims that she was forced to work in a capacity above her job classification for extended periods of time “without an increase in

2 Defendants filed a motion to strike Stewart’s unauthorized sur-response. (ECF No. 49). While Stewart should have first obtained leave of court, given her pro se status, the Court hereby DENIES Defendants’ motion to strike (ECF No. 49) and will consider her sur-reply. In any case, as discussed below, the Court’s recommendation is based on whether Stewart’s complaint alleges sufficient factual allegations to state a plausible claim for relief.

3 In their motion to dismiss, Defendants’ cite to the allegations and exhibits contained in both Stewart’s initial complaint (ECF No. 1) and amended complaint (ECF No. 37) in discussing the factual basis for her claims and in arguing for dismissal. Consistent with that approach, while Stewart’s amended complaint in ECF No. 37 is the operative complaint, the Court will sometimes cite to Stewart’s initial complaint to provide additional context when explaining her claims.

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Bluebook (online)
Stewart v. Wayne County Probate Court, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stewart-v-wayne-county-probate-court-mied-2025.