Warren v. University of Arizona

CourtDistrict Court, D. Arizona
DecidedOctober 3, 2024
Docket2:24-cv-02014
StatusUnknown

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

Bluebook
Warren v. University of Arizona, (D. Ariz. 2024).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 De Antoine Warren, No. CV-24-02014-PHX-JJT

10 Plaintiff, ORDER

11 v.

12 University of Arizona, et al.,

13 Defendants. 14 15 In prior Orders, the Court granted pro se Plaintiff De Antoine Warren’s Application 16 to Proceed in District Court Without Prepaying Fees or Costs (Doc. 9) but required him to 17 refile his Complaint because the filed versions contained text that was cut off (Docs. 9, 11). 18 Now, as Plaintiff has filed an Amended Complaint containing untruncated factual 19 allegations (Doc. 12, Am. Compl.), the Court will screen it pursuant to 28 U.S.C. 20 § 1915(e)(2). 21 I. LEGAL STANDARDS 22 A. 28 U.S.C. § 1915(e)(2) 23 For cases in which a party is permitted to proceed in forma pauperis—that is, the 24 party lacks the means to pay court fees—Congress provided that a district court “shall 25 dismiss the case at any time if the court determines” that the “allegation of poverty is untrue” 26 or that the “action or appeal” is “frivolous or malicious,” “fails to state a claim on which 27 relief may be granted,” or “seeks monetary relief against a defendant who is immune from 28 such relief.” 28 U.S.C. § 1915(e)(2). Section 1915(e) applies to all in forma pauperis 1 proceedings. Lopez v. Smith, 203 F.3d 1122, 1129 (9th Cir. 2000). “It is also clear that section 2 1915(e) not only permits but requires a district court to dismiss an in forma pauperis 3 complaint that fails to state a claim.” Id. at 1127. 4 B. Rule 8, Federal Rules of Civil Procedure 5 A complaint must include “a short and plain statement of the claim showing that the 6 pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). The complaint must contain “sufficient 7 factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” 8 Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 9 544, 570 (2007)). A dismissal for failure to state a claim can be based on either (1) the lack 10 of a cognizable legal theory or (2) insufficient facts to support a cognizable legal claim. 11 Balistreri v. Pacifica Police Dep’t, 901 F.2d 696, 699 (9th Cir. 1990). Rule 8(a) also 12 provides that “[a] pleading that states a claim for relief must contain: (1) a short and plain 13 statement of the grounds for the court’s jurisdiction.” In other words, to proceed in federal 14 court, a plaintiff must allege enough in the complaint for the court to conclude it has subject 15 matter jurisdiction. See Charles Alan Wright & Arthur R. Miller, 5 Fed. Practice & 16 Procedure § 1206 (3d ed. 2014). 17 Even where a complaint has the factual elements of a cause of action present but 18 scattered throughout the complaint and not organized into a “short and plain statement of the 19 claim,” it may be dismissed for failure to satisfy Rule 8(a). Sparling v. Hoffman Constr. Co., 20 864 F.2d 635, 640 (9th Cir. 1988). Moreover, “[e]ach allegation must be simple, concise, 21 and direct.” Fed. R. Civ. P. 8(d)(1). 22 II. ANALYSIS 23 In the Amended Complaint (Doc. 12, Am. Compl.), Plaintiff alleges he is a 24 51-year-old African American man with disabilities of “Mental Health/Dispression 25 [sic]/Anxiety.” (Am. Compl. at 4.) He raises claims against Defendants University of 26 Arizona Global Campus and four individuals under Title VII, the Age Discrimination in 27 Employment Act (“ADEA”), the Americans with Disabilities Act (“ADA”), and under state 28 law for “Falsifying Document/Character Defamation.” (Am. Compl. at 3.) As a factual basis 1 for these claims, Plaintiff states conclusorily that the University of Arizona Global Campus 2 treated him unfairly, engaged in discriminatory practices, denied “[r]equests to transfer 3 teams,” and “exhibited favoritism, lack of compassion, and unwarranted disciplinary 4 actions” during Plaintiff’s time of grieving following the loss of his eldest son. (Am. Compl. 5 at 4.) The Amended Complaint suffers from myriad defects and deficiencies, including the 6 following: 7 A. The University of Arizona is a non-jural entity. 8 In Arizona, a plaintiff may sue a government entity only if it is a jural entity, that is, 9 the state legislature has granted that entity the power to sue or be sued. Braillard v. Maricopa 10 County, 232 P.3d 1263, 1269 (Ariz. Ct. App. 2010). The University of Arizona is a non-jural 11 entity under Arizona law and “cannot be sued in its own name.” Ansel Adams Publ’g Rts. 12 Tr. v. PRS Media Partners, LLC, 502 F. App’x 659, 660 (9th Cir. 2012). Instead, “the 13 Arizona Board of Regents (Board), as the governing body for Arizona’s public universities, 14 is the proper defendant for all actions against the University.” Id. As a result, Plaintiff cannot 15 sue the University of Arizona Global Campus, and the Court will dismiss Plaintiff’s claims 16 against it. 17 B. Plaintiff does not allege that he exhausted his administrative remedies. 18 To seek relief under Title VII, a plaintiff must first exhaust any administrative 19 remedy available under 42 U.S.C. § 2000e-5 by filing a charge with the Equal Employment 20 Opportunity Commission (EEOC). Surrell v. Ca. Water Serv. Co., 518 F.3d 1097, 1104 21 (9th Cir. 2008). The plaintiff must file the charge of discrimination within 180 or 300 days 22 “after the alleged unlawful employment practice occurred,” depending on whether the 23 plaintiff first instituted proceedings with a state or local agency. 42 U.S.C. § 2000e-5(e)(1). 24 The EEOC must issue a right-to-sue letter before the plaintiff can file a Title VII suit in 25 federal court. Karim-Panahi v. L.A. Police Dep’t, 839 F.2d 621, 626 (9th Cir. 1988); 26 42 U.S.C. § 2000e-5(f)(1). 27 The ADEA also requires a plaintiff to file a discrimination charge with the EEOC 28 before bringing a civil action: “No civil action may be commenced by an individual under 1 this section until 60 days after a charge alleging unlawful discrimination has been filed with 2 the [EEOC].” 29 U.S.C. § 626. Also, before a plaintiff may file an ADA discrimination 3 claim in federal court, he must file a charge of discrimination with the EEOC. See Fort 4 Bend County v. Davis, 139 S. Ct. 1843, 1851 (2019) (holding that the charge-filing 5 requirement is a mandatory processing rule); Santa Maria v. Pac. Bell, 202 F.3d 1170

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Warren v. University of Arizona, Counsel Stack Legal Research, https://law.counselstack.com/opinion/warren-v-university-of-arizona-azd-2024.