Tatum v. Illinois Central School Bus LLC

CourtDistrict Court, E.D. Missouri
DecidedMarch 24, 2025
Docket4:23-cv-01219
StatusUnknown

This text of Tatum v. Illinois Central School Bus LLC (Tatum v. Illinois Central School Bus LLC) 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
Tatum v. Illinois Central School Bus LLC, (E.D. Mo. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

KAREN TATUM, ) ) Plaintiff, ) ) vs. ) Case No. 4:23 CV 1219 RWS ) ILLINOIS CENTRAL SCHOOL BUS ) LLC d/b/a NORTH AMERICA ) CENTRAL SCHOOL BUS LLC, d/b/a ) MISSOURI CENTRAL SCHOOL BUS, ) LLC, et al., ) ) Defendants. )

MEMORANDUM AND ORDER This matter is before the Court on the unopposed motion to dismiss filed by defendant Laborers’ International Union of North America, Local 773 (Union).1 Plaintiff was granted leave to amend her complaint in this employment discrimination case to add the Union as a defendant because she represented to the Court that she had filed a Charge of Discrimination against, and obtained a right-to- sue letter for, the Union. ECF 77. Plaintiff had previously been instructed that if she were attempting to sue the Union “under Title VII, the ADA, or the ADEA, she

1 Plaintiff, a self-represented litigant, was granted a substantial extension of time to respond to the Union’s motion to dismiss. ECF 143. Despite the extension of time, plaintiff failed to file an opposition to the motion to dismiss, and her time for doing so has now expired. Plaintiff was warned that her failure to timely respond would result in the Court’s consideration of the motion without further notice. Id. would have had to first filed a Charge of Discrimination against the union (not just the North American Central School Bus, LLC) at the EEOC, and then obtained a

Right to Sue.” ECF 5 at 10 n.3. To the extent the Second Amended Complaint brings employment discrimination claims against the Union,2 it now moves to dismiss them3 for

plaintiff’s failure to exhaust administrative remedies. The Union maintains that plaintiff has not, in fact, named it as a charged party in a Charge of Discrimination filed with the EEOC or obtained a Right to Sue letter as to any such Charge. The Union’s unopposed motion is well-taken. The only Charge of Discrimination

provided by plaintiff appears in the record as ECF 1-5 and names only the North American Central School Bus LLC and the Illinois Central School Bus LLC companies (which are actually the same defendant) as the charged party. Plaintiff

was previously instructed that this Charge of Discrimination was insufficient to bring discrimination claims against the Union. ECF 5 at 10 n.3. Plaintiff was further

2 Plaintiff’s Second Amended Complaint alleges failure to accommodate, retaliation and discrimination in violation of the Americans with Disabilities Act (ADA) (Counts I, II, and VI), age discrimination in violation of the Age Discrimination in Employment Act (ADEA) (Count III), and a “hostile work environment” under the ADA and ADEA. (Count V). ECF 78. The Counts are alleged against defendants, but the allegations (except for one allegation in Count V) relate solely to actions taken by defendant’s employer, not the Union. In Count V, plaintiff alleges that defendants conspired to dismiss her grievances. Id. at 35. Count IV alleges a breach of the collective bargaining agreement by the Union. Id. at 29.

3 The Union cites Federal Rules of Civil Procedure 12(b)(1) and (6) in its motion, but failure to exhaust an administrative remedy does not deprive the Court of subject matter jurisdiction. This motion is decided under Fed. R. Civ. P. (b)(6) only. instructed that to avoid dismissal she must “include as exhibits the complete charge of discrimination plaintiff alleges she filed against the defendant union, together with

a complete copy of the right to sue letter issued on the charge demonstrating that the union was a charged party.” ECF 143. Plaintiff has failed to provide such information despite repeated notice and ample opportunity to do so. Id.

Under Federal Rule of Civil Procedure 12(b)(6), a party may move to dismiss a claim for “failure to state a claim upon which relief can be granted.” The notice pleading standard of Federal Rule of Civil Procedure 8(a)(2) requires a plaintiff to give “a short and plain statement showing that the pleader is entitled to relief.” To

meet this standard and to survive a Rule 12(b)(6) 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.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (internal

quotations and citation omitted). This requirement of facial plausibility means the factual content of the plaintiff’s allegations must “allow[ ] the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Park Irmat Drug Corp. v. Express Scripts Holding Co., 911 F.3d 505, 512 (8th Cir. 2018)

(quoting Iqbal, 556 U.S. at 678). The Court must grant all reasonable inferences in favor of the nonmoving party. Lustgraaf v. Behrens, 619 F.3d 867, 872-73 (8th Cir. 2010). Ordinarily, only the facts alleged in the complaint are considered for

purposes of a motion to dismiss; however, materials attached to the complaint may also be considered in construing its sufficiency. Reynolds v. Dormire, 636 F.3d 976, 979 (8th Cir. 2011).

When ruling on a motion to dismiss, a court “must liberally construe a complaint in favor of the plaintiff.” Huggins v. FedEx Ground Package Sys., Inc., 592 F.3d 853, 862 (8th Cir. 2010). However, if a claim fails to allege one of the

elements necessary to recover on a legal theory, the Court must dismiss that claim for failure to state a claim upon which relief can be granted. Crest Constr. II, Inc. v. Doe, 660 F.3d 346, 355 (8th Cir. 2011). Threadbare recitals of a cause of action, supported by mere conclusory statements, do not suffice. Iqbal, 556 U.S. at 678;

Bell Atlantic v. Twombly, 550 U.S. 544, 555 (2007). Although courts must accept all factual allegations as true, they are not bound to take as true a legal conclusion couched as a factual allegation. Twombly, 550 U.S. at 555 (internal quotations and

citation omitted); Iqbal, 556 U.S. at 677–78. The anti-discrimination statutes cited in plaintiff’s second amended complaint require a plaintiff to timely file a charge of discrimination with the EEOC before filing suit in federal court. See 42 U.S.C. § 12117(a) (ADA); Section 2000e-5(e)(1)

(Title VII); 29 U.S.C. § 626(d)(1)(A) (ADEA). “The purpose of filing a charge with the EEOC is to provide the Commission an opportunity to investigate and attempt a resolution of the controversy through conciliation before permitting the aggrieved

party to pursue a lawsuit.” Cobb v. Stringer, 850 F.2d 356, 359 (8th Cir. 1988) (citations omitted). Thus, “as a general rule, a complainant must file a charge against a party with the EEOC before she can sue that party.” Sedlacek v. Hach, 752 F.2d

333, 336 (8th Cir.

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Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Lustgraaf v. Behrens
619 F.3d 867 (Eighth Circuit, 2010)
Reynolds v. Dormire
636 F.3d 976 (Eighth Circuit, 2011)
Crest Construction II, Inc. v. Doe
660 F.3d 346 (Eighth Circuit, 2011)
Huggins v. FedEx Ground Package System, Inc.
592 F.3d 853 (Eighth Circuit, 2010)
Moses v. Dassault Falcon Jet-Wilmington Corp
894 F.3d 911 (Eighth Circuit, 2018)
Park Irmat Drug Corp. v. Express Scripts Holding Co.
911 F.3d 505 (Eighth Circuit, 2018)
Paul Voss v. Housing Authority, etc.
917 F.3d 618 (Eighth Circuit, 2019)
Sedlacek v. Hach
752 F.2d 333 (Eighth Circuit, 1985)
Cobb v. Stringer
850 F.2d 356 (Eighth Circuit, 1988)

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Tatum v. Illinois Central School Bus LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tatum-v-illinois-central-school-bus-llc-moed-2025.