Tiffany Torres v. Fayetteville State University

CourtDistrict Court, E.D. North Carolina
DecidedMarch 20, 2026
Docket5:25-cv-00130
StatusUnknown

This text of Tiffany Torres v. Fayetteville State University (Tiffany Torres v. Fayetteville State University) is published on Counsel Stack Legal Research, covering District Court, E.D. North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tiffany Torres v. Fayetteville State University, (E.D.N.C. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA WESTERN DIVISION No. 5:25-CV-130-BO-BM

TIFFANY TORRES, ) Plaintiff, V. ORDER FAYETTEVILLE STATE UNIVERSITY, Defendant.

This cause comes before the Court defendant’s motions to dismiss plaintiff's original and amended complaints. [DE 12]; [DE 20]. The appropriate responses and replies have been filed, or the time for doing so has expired, and in this posture both motions are ripe for disposition. For the reasons that follow, defendant's motion to dismiss the original complaint is denied as moot and its motion to dismiss the amended complaint is granted in part and denied in part. BACKGROUND Plaintiff commenced this action alleging discrimination claims against defendant, her employer. In her amended complaint, plaintiff alleges that she is a current employee in defendant’s Charles W. Chesnutt Library (Library). Plaintiff, an Afro-Latina woman, began her employment at the Library in June 2022 as a Work Reference Librarian. Plaintiff was promoted to Head of Reference in 2023, at which time she began to speak out against the disparate and discriminatory treatment of library employees of color. Plaintiff also complained about the hostile work environment created by Lawrence Treadwell, Director of Library Services,' and other white library

' Lawrence Treadwell is identified in the amended complaint as Treadwell. Plaintiff's opposition to the motion to dismiss includes Treadwell’s first name and job title. See [DE 24].

employees. Plaintiff alleges that, beginning in January 2024, she contacted Treadwell regarding additional tasks that had been assigned to African American reference staff that were not within the staff members’ job description. In response, Treadwell and Jessica Cerri, Head of Public Services, assigned additional tasks to plaintiff. Plaintiff alleges that Treadwell and Cerri also knew that plaintiff was a witness in employment discrimination and retaliation cases against defendant. Plaintiff reported the harassment of two LGBTQ+ librarians by a graduate student to human resources in February 2024 and alleges that she was again given additional assignments and tasks by Treadwell and Cerri in retaliation for making a report to human resources. Plaintiff spoke about her concerns within the Library during an April 2024 staff townhall meeting with the University Chancellor and wrote an article for the school’s newsletter about the townhall meeting. Plaintiff again complained to human resources after witnessing another library employee be berated and mistreated by Treadwell during a meeting in June 2024. Plaintiff alleges that she was again subjected to increased workload, including a project with an untenable and burdensome completion deadline, and that Treadwell also removed key library staff from the reference desk rotation, placing increased workload on certain Jibrary staff of color. Plaintiff submitted another formal complaint to human resources and defendant’s legal department in January 2025. Plaintiff alleges two claims for relief in her amended complaint: retaliation in violation of Title VII for engaging in protected activity by reporting Treadwell’s discriminatory conduct against African American and older employees and hostile work environment in violation of Title VII due to retaliation. Defendant has moved to dismiss plaintiff's amended complaint pursuant to Rules 12(b)(1), 12(b)(2), and 12(b)(6) of the Federal Rules of Civil Procedure.

DISCUSSION At the outset, in light of the filing of an amended complaint, defendant’s motion to dismiss the original complaint [DE 12] is denied as moot. See Fawzy v. Wauquiez Boats SNC, 873 F.3d 451, 455 (4th Cir. 2017) (amended pleading renders original of no effect). Federal Rule of Civil Procedure 12(b)(1) authorizes dismissal of a claim for lack of subject matter jurisdiction. When subject matter jurisdiction is challenged, the plaintiff has the burden of proving jurisdiction to survive the motion. Evans v. B.F. Perkins Co., 166 F.3d 642, 647-50 (4th Cir. 1999). “In determining whether jurisdiction exists, the district court is to regard the pleadings’ allegations as mere evidence on the issue, and may consider evidence outside the pleadings without converting the proceeding to one for summary judgment.” Richmond, Fredericksburg & Potomac R.R. Co. v. United States, 945 F.2d 765, 768 (4th Cir. 1991). Rule 12(b)(2) of the Federal Rules of Civil Procedure authorizes dismissal for lack of personal jurisdiction. When personal jurisdiction has been challenged on the papers alone, the plaintiff must make a prima facie case showing that personal jurisdiction exists, and a court construes all facts and inferences in favor of finding jurisdiction. Combs v. Bakker, 886 F.2d 673, 676 (4th Cir. 1989). A Rule 12(b)(6) motion to dismiss for failure to state a claim upon which relief can be granted tests the complaint’s legal and factual sufficiency. See Fed. R. Civ, P. 12(b)(6). The focus is on the pleading requirements under the Federal Rules, not the proof needed to succeed on a claim. “Federal Rule of Civil Procedure 8(a)(2) requires only a short and plain statement of the claim showing that the pleader is entitled to relief, in order to give the deferdant fair notice of what the claim is and the grounds upon which it rests.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (cleaned up). This standard does not require detailed factual allegations, id., but it “demands more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Nadendla_v.

WakeMed, 24 F.4th 299, 305 (4th Cir. 2022) (citation omitted). “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 Twombly, 550 U.S. at 570). Fora claim to be plausible, its factual content must permit the court to “draw the reasonable inference that the defendant is liable for the misconduct alleged.” /d. Defendant makes the following arguments in support of dismissal of plaintiff's complaint: first, that Title VI] does not prohibit employment discrimination based on age; second, that plaintiff has failed to exhaust portions of her claims; third. that most of plaintiff's retaliation claim is untimely; fourth, that plaintiff has failed to plausibly allege any adverse employment action and has thus failed to state a retaliation claim; and fifth, that plaintiff has failed to plausibly allege a claim for hostile work environment. Plaintiff has confirmed in her opposition that she has not brought a claim based on age discrimination and has conceded dismissal of any claim for retaliation related to age by failing to oppose defendant’s motion on this issue. See Kinetic Concepts, Inc. v.

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Tiffany Torres v. Fayetteville State University, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tiffany-torres-v-fayetteville-state-university-nced-2026.