Tiandra Vaccianna v. University of Miami

District Court, S.D. Florida·Decided August 24, 2026·No. 1:25-cv-24636·Unknown

Opinion

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA Miami Division Case Number: 25-24636-CIV-MORENO TIANDRA VACCIANNA, Plaintiff, vs. UNIVERSITY OF MIAMI, Defendant. eee ORDER GRANTING IN PART AND DENYING IN PART DEFENDANT’S MOTION TO DISMISS This case involves an employment discrimination action arising from Plaintiff Tiandra Vaccianna’s allegations that Defendant University of Miami failed to accommodate her disability and interfered with her use of medical leave. Plaintiff brings six claims under the Florida Civil Rights Act, the Americans With Disabilities Act, and the Family and Medical Leave Act for failure to accommodate, interference, and retaliation. The Court grants the Motion to Dismiss as to Counts I and II because Plaintiff fails to sufficiently allege that she was a qualified individual capable of performing the essential functions of her position, with or without accommodation. The Court denies the Motion as to all remaining Counts. FACTUAL BACKGROUND Defendant hired Plaintiff in October 2021 as a Customer Service Representative. In August 2022, Plaintiff began working as a Contact Center Associate for Defendant. Plaintiff has sickle-cell anemia, which she alleges substantially limits circulation, energy, and concentration

and requires ongoing treatment, monitoring, transfusions, hospitalization, and intermittent leave. Plaintiff disclosed her condition to Defendant and sought intermittent medical leave. By December 2022, Plaintiff alleges that she was eligible and approved for intermittent leave under the Family and Medical Leave Act (“FMLA”). In June 2023, Plaintiff contends that Supervisor Deana Oneto denied her protected medical-leave requests. Plaintiff complained to Human Resources, and according to her Complaint, Human Resources agreed that the denials were improper. Plaintiff was then reassigned to Supervisor Caral Avalos. Despite the reassignment, Plaintiff alleges that Defendant continued requiring repeated and unnecessary medical documentation, giving her attendance warnings, and treating her requests negatively. In January 2024, Plaintiff suffered a medical emergency requiring hospitalization, a cerebral angiogram, and a blood transfusion. She contends that her physician required a follow-up appointment on January 25, 2024, to monitor for a delayed transfusion reaction. Plaintiff states that Defendant refused to approve her absence because that date had not been specifically listed on her earlier medical certification. According to Plaintiff, this omission was outside of her control because of the nature of the medical emergency requiring the initial hospitalization. Plaintiff alleges that Defendant indicated the absence would be unprotected and subject to its attendance point system, placing Plaintiff at risk of discipline and termination. Because she feared accumulating attendance points and suffering disciplinary action, Plaintiff worked on January 25, 2024, rather than attending the follow up appointment. That night, Plaintiff alleges she suffered a sickle-cell crisis and was hospitalized from January 26, 2024, through February 6, 2024, with life-

_ threatening complications. During her hospitalization, Plaintiff alleges that Human Resources representatives repeatedly called, texted, and emailed Plaintiff, demanding that she log into her work computer,

complete her timesheets, and submit additional medical paperwork. Plaintiff alleges that these communications occurred while she was sedated and receiving treatment, interfering with her recovery. On February 5, 2024, while Plaintiff was still hospitalized, Plaintiff emailed Human Resources Representative Savoy Smith and complained about the communications, requesting an accommodation to respond to all requests after she had recovered. Still, Plaintiff contends that the demands continued. Fearing further interference of her rights and harm to her health and wellbeing, Plaintiff resigned on February 12, 2024. PROCEDURAL HISTORY After her resignation, Plaintiff filed an Equal Employment Opportunity Commission (“EEOC”) Charge of Discrimination and was issued a Right to Sue Letter. Plaintiff filed her Complaint in the Circuit Court of the Eleventh Judicial Circuit in and for Miami-Dade County Florida. Defendant timely removed the action to this Court and filed a Motion to Dismiss the Complaint. Thereafter, Plaintiff filed an Amended Complaint, bringing six counts against Defendant. Defendant filed the underlying Motion to Dismiss. LEGAL STANDARD “A pleading that states a claim for relief must contain... a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). 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.’” 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.” /d. (citing Twombly, 550 U.S. at 556). “While legal conclusions can provide the framework of a complaint, they must be supported by factual allegations.” Jd. at

679. Detailed factual allegations are not required, but a complaint must offer more than “labels and conclusions” or “a formulaic recitation of the elements of the cause of action.” Twombly, 550 USS. at 555 (citation omitted). The factual allegations must be enough to “raise a right to relief above the speculative level.” /d. (citations omitted). DISCUSSION Defendant argues both that Plaintiff has failed to exhaust her administrative remedies and that she fails to state a plausible cause of action as to each count of the Amended Complaint. The Court addresses all arguments below. I. Plaintiff Exhausted Her Administrative Remedies Defendant argues that Plaintiff's EEOC Charge is premised on claims of retaliation and failure-to-accommodate during a six-week period in early 2024. Thus, Defendant contends, Plaintiff has failed to exhaust her administrative remedies as to all allegations outside the scope of her EEOC Charge, i.e., as to all claims under the ADA and the Florida Civil Rights Act (““FCRA”) that include allegations beyond the six-week period noted in her EEOC Charge. Plaintiff responds that any facts alleged in the Complaint outside the six-week scope were included as background evidence to illuminate the meaning of Defendant’s later actions. To begin, the Court notes that Plaintiffs EEOC Charge is not an attachment to her Amended Complaint. Defendant attached Plaintiffs sworn EEOC Charge to its Motion as Exhibit A. Plaintiff does not argue against the inclusion of the EEOC Charge. Further, the Court may consider the EEOC Charge “without converting the motion to dismiss into a motion for summary judgment because it is “(1) central to the plaintiff's claims; and (2) undisputed, meaning that its authenticity is not challenged.” Veritas v. Cable News Network, Inc., 121 F.4th 1267, 1272 n.5 (11th Cir. 2024) (quoting Johnson v. City of Atlanta, 107 F.4th 1292, 1300 (11th Cir. 2024)).

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