Law School Case Brief
Alridge v. Rite Aid of Wash., D.C., Inc. - 146 F. Supp. 3d 242 (D.D.C. 2015)
To survive a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), the complaint must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.
Plaintiff, John Alridge had worked for defendant Rite Aid of Washington, D.C., Inc. ("Rite Aid") for several years when, in Nov. 2011, he was transferred to another location. From that time until Feb. 2012, Aldridge claimed he suffered various and numerous types of discriminatory and retaliatory behavior, including harassment, false accusations of theft and drug and alcohol abuse, and repeated retaliation by management for his attempts to report the discriminatory behavior. In Feb. 2012, Alridge was transferred to yet another location, which was farther away from his home. On March 28, 2012, Alridge filed a charge of discrimination with the Equal Employment Opportunity Commission ("EEOC"), alleging discrimination based on national origin and retaliation. On Aug. 15, 2013, the EEOC notified Alridge that it was unable substantiate violations of federal law, but also notified him of his right to sue within 90 days after receiving the notice. On Nov. 15, 2013, Alridge filed a complaint against Rite Aid in federal district court, but he did not pay the requisite filing fee and his application to proceed in forma pauperis was denied on Nov. 21, 2013; Alridge was notified by the court that his lawsuit had not been filed. On Nov. 19, 2014, Alridge paid the requisite filing fee and filed another pro se complaint against Rite Aid alleging employment discrimination, defamation and violations of his Thirteenth and Fourteenth Amendment rights. Rite Aid filed a motion to dismiss the complaint under Federal Rule of Civil Procedure 12(b)(6).
Did Alridge's complaint state a cause of action against Rite Aid?
The court granted Rite Aid's motion to dismiss. The court ruled, inter alia, that: (1) Alridge's discrimination and retaliation claims were time-barred because Alridge neither diligently pursued his rights against Rite Aid nor demonstrated any extraordinary circumstances preventing him from doing so. (2) The District of Columbia provided a one-year limitations period for defamation claims, and the defamation alleged by Alridge occurred no later than Feb. 2012. As Alridge did not file the instant lawsuit until Nov. 19, 2014, his defamation was claim was time-barred and thus subject to dismissal. (3) There was no private right of action for involuntary servitude under the Thirteenth Amendment, and thus that claim was dismissed. (4) Alridge's claim under the Fourteen Amendment failed because that Amendment applied only to state actors, not private parties, and Rite Aid was not a state actor.
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