Law School Case Brief
Morris v. David Lerner Assocs. - 680 F. Supp. 2d 430 (E.D.N.Y. 2010)
To survive a Fed. R. Civ. P. 12(b)(6) motion, plaintiff need not establish a prima facie case of discrimination, but her complaint must give fair notice of her claims, and those claims must be facially plausible.
Plaintiff Dora Morris was a former employee of defendant David Lerner Associates ("DLA"). She filed a lawsuit in federal district court against DLA and defendant David Lerner, individually, who was DLA's president and Morris' supervisor throughout her tenure at DLA. The lawsuit alleged violations of Title VII of the Civil Rights Act of 1964 and the New York State Human Rights Law. Specifically, Morris alleged that defendants discriminated against her because of her gender by paying her less than similarly situated male co-workers and by subjecting her to a hostile work environment. Morris also alleged that, when she complained to Lerner about the fact that she was being paid less than similarly situated men, she was fired in retaliation for her complaints. Prior to filing the lawsuit, Morris had filed a charge of discrimination with the U.S. Equal Employment Opportunity Commission ("EEOC") and subsequently received a right to sue letter from the EEOC. Defendants filed a motion for partial dismissal of the complaint on the grounds that Morris failed to exhaust her administrative remedies and that, in any event, her allegations regarding the claims failed to state a claim for which relief could be granted.
Should the court grant the motion to dismiss?
Defendants' motion to dismiss was denied. The court rejected defendants' claim that neither Morris' hostile work environment claim nor her retaliation claim was reasonably related to the charge she filed with the EEOC. The court found that because Morris' EEOC charge contained the factual basis for a hostile work environment claim and because the EEOC was clearly aware of those facts, the hostile work environment claim was "reasonably related" to the sex discrimination claim raised in her EEOC charge. As such, her hostile work environment claim was considered exhausted for purposes of her lawsuit. Likewise, Morris' retaliation claim was also reasonably related to the charge she filed with the EEOC. Finally, the court ruled, Morris adequately pleaded her claims for hostile work environment and retaliatory termination so as to survive the motion to dismiss. The court observed that she cited a series of sex-based comments that were allegedly made by Lerner to her in the workplace and that such comments were not one-time occurrences. In addition, the complaint clearly alleged that, only days after her discussion with Lerner about her being treated differently than male workers, Morris suffered an adverse employment action when she was terminated.
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