Sullivan v. Atlantic Plant Maintenance

CourtDistrict Court, M.D. Louisiana
DecidedFebruary 5, 2025
Docket3:23-cv-01450
StatusUnknown

This text of Sullivan v. Atlantic Plant Maintenance (Sullivan v. Atlantic Plant Maintenance) is published on Counsel Stack Legal Research, covering District Court, M.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sullivan v. Atlantic Plant Maintenance, (M.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF LOUISIANA

ROY SULLIVAN CIVIL ACTION VERSUS NO. 23-1450-JWD-RLB ATLANTIC PLANT MAINTENANCE

RULING AND ORDER

This matter comes before the Court on the Motion to Dismiss, (Doc. 25), filed by Defendant Atlantic Plant Maintenance (“Defendant”). Plaintiff Roy Sullivan (“Plaintiff”) has responded with a Memorandum in Opposition to Motion to Dismiss (“Pl. Opposition”), (Doc. 28), and Defendant has filed a Reply Memorandum in Support of Motion to Dismiss (“Def. Reply”), (Doc. 32). I. BACKGROUND At this stage in the pleadings, the Court accepts Plaintiff’s well-pleaded allegations. Plaintiff is an African-American man who was formerly employed by Defendant but left this employment following alleged discrimination in September through October of 2021. (Doc. 18 at ¶¶ 2–4, 7.) Plaintiff alleges that while employed by Defendant, he was discriminated against on account of his race. (Id. at ¶ 4.) Specifically, Plaintiff alleges that he, as an African-American employee, was subject to disparate treatment compared to Caucasian employees. (Id. at ¶¶ 3, 5– 6.) He claims first that unlike a white employee, he was not “given additional time to complete computer based training” and was “threatened with termination if he did not complete the training within the specified time period[,]” and second that he was “subjected to write-up for meeting with the computer based trainer at a particular location whereas Caucasian employees were not written- up for meeting the trainer at the same location.” (Id.) Plaintiff alleges that this created a hostile work environment, forcing him to leave Defendant employer and to file a union grievance against Defendant. (Id. at ¶¶ 7–8.) Plaintiff claims that following his filing of this grievance, he was blackballed from further employment by Defendant as a result of a conspiracy by Defendant and Union officers. (Id. at ¶ 8–9.) As a result, Plaintiff sues Defendant for conspiracy in violation of 42 U.S.C. §§ 1981 and 1985; for a violation of his First Amendment right to free speech in violation of § 1981; for disparate treatment, hostile work environment, and retaliation in violation of Title

VII of the Civil Rights Act of 1964; and for intentional infliction of emotional distress. (Id. at ¶¶ 11–38.) II. PARTIES’ ARGUMENTS Defendant argues that Plaintiff’s claims should be dismissed pursuant to Rule 12(b)(6) for failure to state a claim upon which relief can be granted. (Doc. 25 at 1.) Defendant argues that Plaintiff has failed to sufficiently allege that race was the cause of any of the incidents he complains of, and furthermore that he has failed to allege that his treatment was sufficiently severe or pervasive to state a claim. (Doc. 25-1 at 10–11.) Defendant additionally contends that Plaintiff has failed to adequately allege retaliation, either in the form of being denied employment or work assignments at Defendant. (Id. at 11–13.) Defendant maintains that Plaintiff has also not

sufficiently alleged facts to claim disparate treatment or conspiracy; that he cannot claim a First Amendment violation against Defendant, a private actor; and that he has not alleged actions that rise to intentional infliction of emotional distress. (Doc. 25-1 at 8, 13–21.) In response, Plaintiff argues that “[b]ecause of the discrimination complaints filed by Mr. Sullivan, Atlantic retaliated against Mr. Sullivan, conspired with his Union[,] and refused to hire Mr[.] Sullivan for subsequent work assignments.” (Doc. 28 at 1.) He further alleges that “because of his race, he was treated differently than a white employee.” (Id. at 2.) Plaintiff provides affidavits and emails that he claims support his action. (Docs. 30-1, 30-2, 30-3, 30-4, 30-5, 30-6, 30-7, 30- 8, 30-9.) Defendant replies that Plaintiff has opposed only the dismissal of his claims for race discrimination and retaliation, not the claims for conspiracy, First Amendment violations, or state law claims. (Doc. 32 at 1.) With respect to the race discrimination and retaliation claims, Defendant argues that Plaintiff has still failed to allege sufficient facts to state a claim for relief. (Id. at 1–2.)

Specifically, Defendant argues that Plaintiff has failed to allege an adverse employment action, failed to adequately point to race as the basis of any negative treatment, and failed to demonstrate protected activity that would give rise to retaliation. (Id. at 3–5.) III. LEGAL STANDARDS A. Motion to Dismiss “To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Hamilton v. Dall. Cnty., No. 21-10133, 2023 WL 5316716, at *3 (5th Cir. Aug. 18, 2023) (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007))). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the

reasonable inference that the defendant is liable for the misconduct alleged.” Id. (quoting Iqbal, 556 U.S. at 678). “To be plausible, the complaint’s ‘[f]actual allegations must be enough to raise a right to relief above the speculative level.’” In re Great Lakes Dredge & Dock Co. LLC, 624 F.3d 201, 210 (5th Cir. 2010) (quoting Twombly, 550 U.S. at 555). “In deciding whether the complaint states a valid claim for relief, we accept all well-pleaded facts as true and construe the complaint in the light most favorable to the plaintiff.” Id. (citing Doe v. MySpace, Inc., 528 F.3d 413, 418 (5th Cir. 2008)). The Court does “not accept as true ‘conclusory allegations, unwarranted factual inferences, or legal conclusions.’” Id. (quoting Ferrer v. Chevron Corp., 484 F.3d 776, 780 (5th Cir. 2007)). “A claim for relief is implausible on its face when ‘the well-pleaded facts do not permit the court to infer more than the mere possibility of misconduct.’” Harold H. Huggins Realty, Inc. v. FNC, Inc., 634 F.3d 787, 796 (5th Cir. 2011) (citing Iqbal, 556 U.S. at 679). The Court’s “task, then, is ‘to determine whether the plaintiff has stated a legally cognizable

claim that is plausible, not to evaluate the plaintiff’s likelihood of success.’” Doe v. Covington Cnty. Sch. Dist., 675 F.3d 849, 854 (5th Cir. 2012) (quoting Lone Star Fund V (U.S.), L.P. v. Barclays Bank PLC, 594 F.3d 383, 387 (5th Cir. 2010) (citing Iqbal, 556 U.S. at 678)). “[A] claim is plausible if it is supported by ‘enough fact[s] to raise a reasonable expectation that discovery will reveal evidence of [the alleged misconduct].’” Calhoun v. City of Houston Police Dep’t, 855 F. App’x 917, 919–20 (5th Cir. 2021) (per curiam) (quoting Twombly, 550 U.S. at 556). Additionally, “[i]n determining whether a plaintiff’s claims survive a Rule 12(b)(6) motion to dismiss, the factual information to which the court addresses its inquiry is limited to (1) the facts set forth in the complaint, (2) documents attached to the complaint, and (3) matters of which judicial notice may be taken under Federal Rule of Evidence 201.” Inclusive Cmtys. Project, Inc.

v. Lincoln Prop. Co., 920 F.3d 890, 900 (5th Cir.

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Sullivan v. Atlantic Plant Maintenance, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sullivan-v-atlantic-plant-maintenance-lamd-2025.