Thomas v. Metropolitan St. Louis Sewer District

District Court, E.D. Missouri·Decided August 14, 2025·No. 4:24-cv-01724·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

JABBAR A. THOMAS, ) ) Plaintiff, ) ) v. ) No. 4:24-CV-01724-JAR ) METROPOLITAN ST. LOUIS ) SEWER DISTRICT, ) ) Defendant. )

MEMORANDUM AND ORDER This matter is before the Court on three motions: (1) Defendant Metropolitan St. Louis Sewer District’s motion to dismiss [ECF No. 9]; (2) Defendant’s motion to strike Plaintiff Jabbar Thomas’ surresponse to Defendant’s motion to dismiss [ECF No. 19]; and (3) Plaintiff’s motion for appointment of counsel [ECF No. 3]. For the reasons stated below, Defendant’s motion to dismiss will be granted, Defendant’s motion to strike Plaintiff’s surresponse will be denied, and Plaintiff’s motion for appointment of counsel will be denied. Background Plaintiff began his employment with Defendant in August 2009. On September 25, 2024, Plaintiff filed a Charge of Discrimination (“Charge”) against Defendant with the Equal Employment Opportunity Commission (“EEOC”). The Charge alleges retaliation and discrimination based on genetic information and race, and it identifies the earliest date of discrimination as November 11, 2023 and the latest date of discrimination as January 10, 2024 [ECF No. 9-1 at 1]. The Charge narrative includes the following: On or around 8/03/2009 I was hired by the above-named supervisor as an Assistant Operations Supervisor. Kelly Hunter, Plant Manager, was my immediate supervisor. I was denied a promotion.

In 12/2023 I applied for the Operation Supervisor's position. I was not interviewed although I was qualified. I was told that I could not be selected for 2 years because I asked for a demotion so I can return to the selected list to be hired at another location. I was told that I was "rigging the system." I was harassed by being accused of smelling like alcohol twice in 9/2023 and 12/2023, so I filed a complaint.

For the above stated reason, I believe that I was not selected because of my race, African American, and for engaging in protected activity in violation of Title VII of the Civil Rights Act of 1964, as Amended (Title VII). and my genetic information in violation of The Genetic Information Nondiscrimination Act of 2008.

[Id.]. On September 26, 2024, the EEOC issued a right to sue letter. Plaintiff filed this pro se employment discrimination action on December 23, 2024. ECF No. 1. In his Complaint, Plaintiff raises claims of employment discrimination under Title VII of the Civil Rights Act of 1964. Plaintiff alleges that his lawsuit involves the failure of Defendant to promote him, the terms and conditions of his employment differing from those of similar employees, retaliation, harassment, and unlawful employment practice. Plaintiff alleges that he was discriminated against because of his race and color. Plaintiff also filed a motion for appointment of counsel [ECF No. 3]. On February 26, 2025, Defendant filed a motion to dismiss and memorandum in support [ECF No. 9]. Defendant argues that Plaintiff’s complaint must be dismissed in its entirety because it lacks facts required to state a claim. Moreover, Defendant states that dismissal is required because Plaintiff failed to exhaust his administrative remedies under Title VII and because many of the claims are time barred. On March 18, 2025, Plaintiff filed a response in opposition to Defendant’s motion to dismiss [ECF No. 13]. On March 28, 2025, Defendant filed a reply to Plaintiff’s response [ECF No. 17]. On April 1, 2025, Plaintiff filed a surresponse [ECF No. 18]. Defendant filed a motion to strike Defendant’s surresponse on the same date [ECF No. 19]. The motions are fully briefed and ready for disposition. Discussion A. Time-Barred Claims Prior to initiating a Title VII action, a plaintiff must file a charge with the EEOC

within 300 days of the event giving rise to the cause of action. 42 U.S.C. § 2000e-5(e)(1). “The existence of past acts and the employee's prior knowledge of their occurrence, however, does not bar employees from filing charges about related discrete acts so long as the acts are independently discriminatory and charges addressing those acts are themselves timely filed. Nor does the statute bar an employee from using the prior acts as background evidence in support of a timely claim.” Nat'l R.R. Passenger Corp. v. Morgan, 536 U.S. 101, 113 (2002). Since Plaintiff filed the Charge on September 25, 2024, the relevant 300-day period preceding the Charge-filing date began November 30, 2023. Plaintiff’s denial of transfer claim and retaliation claim both involve an allegation that on August 25, 2023, Plaintiff sent an email

regarding a vacant Operations Supervisor position, that he was denied the opportunity to transfer, and that the denial was “improper,” “unjust,” and a “blatant act of retaliation” for “filing a claim with the EEOC” [ECF No. 1 at 13]. Defendant thus argues that the denial of transfer claim and retaliation claim should be dismissed because the event giving cause to the claims occurred on August 25, 2023, outside of the 300-day statutory filing period. Citing Nat'l R.R. Passenger Corp., Plaintiff contends in his response in opposition to Defendant’s motion to dismiss that these claims involve “ongoing discriminatory acts, which may constitute a continuing violation.” [ECF No. 13 at 4]. Plaintiff adds that “equitable tolling may apply if Plaintiff was prevented from timely filing due to misleading actions by Defendant or procedural delays beyond his control” [Id. at 4-5]. However, the continuing violation doctrine does not encompass discrete discriminatory acts, such as denial of transfer, which is individually actionable. Taxi Connection v. Dakota, Minnesota & E. R.R. Corp., 513 F.3d 823, 825 (8th Cir. 2008) (citing Nat'l R.R. Passenger Corp., 536 U.S. at 113-14). And regarding the retaliation claim, Plaintiff has not demonstrated in his Complaint or elsewhere that he has been subject to

ongoing discriminatory acts that together are “part of the same unlawful employment practice.” Nat'l R.R. Passenger Corp., 536 U.S. at 122. Moreover, Plaintiff has presented no facts regarding misleading actions by Defendant or procedural delays beyond his control. Therefore, the Court will dismiss Plaintiff’s denial of transfer claim and retaliation claim relating to the above- referenced August 25, 2023 event. B. Failure to Exhaust Administrative Remedies A plaintiff suing under Title VII must first exhaust administrative remedies, meaning he must “give notice of all claims of discrimination in the administrative complaint,” which is the Charge filed with the EEOC. Tart v. Hill Behan Lumber Co., 31 F.3d 668, 671 (8th Cir. 1994).

The Charge must be “sufficiently precise to identify the parties, and to describe generally the action or practices complained of.” 29 C.F.R. § 1601.12(b)). However, “[b]ecause persons filing charges with the EEOC typically lack legal training, those charges must be interpreted with the utmost liberality in order not to frustrate the remedial purposes of Title VII.” Cobb v. Stringer, 850 F.2d 356, 359 (8th Cir. 1988). “Each incident of discrimination and each retaliatory adverse employment decision constitutes a separate actionable unlawful employment practice that must be individually addressed before the EEOC.” Sellers v. Deere & Co., 791 F.3d 938, 943 (8th Cir. 2015) (internal citation omitted).

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Thomas v. Metropolitan St. Louis Sewer District, (E.D. Mo. 2025).

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