McCleary-Evans v. Md. DOT

780 F.3d 582 (4th Cir. 2015)

 

RULE:

The district court's erroneous analysis will not save the complaint if, under the ordinary rules for assessing the sufficiency of a complaint, it fails to state a plausible claim for relief under Title VII of the Civil Rights Act of 1964. While a plaintiff is not required to plead facts that constitute a prima facie case in order to survive a motion to dismiss, factual allegations must be enough to raise a right to relief above the speculative level. 

FACTS:

The petitioner, Dawnn McCleary-Evans, commenced an action against the Maryland Department of Transportation's State Highway Administration, alleging that the Highway Administration failed or refused to hire her for two positions for which she applied because of her race (African American) and her sex (female), in violation of Title VII of the Civil Rights Act of 1964, specifically 42 U.S.C. § 2000e-2(a)(1). In her complaint, she alleged that she was highly qualified for the positions, but that the decision-makers were biased and had "predetermined" that they would select white candidates to fill the positions. In its decision, the district court granted the Highway Administration's motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), concluding that the complaint failed to allege facts that plausibly support a claim of discrimination.

ISSUE:

Did the district court err in its decision to grant the Highway Administration’s motion to dismiss the petitioner’s claim?

ANSWER:

No

CONCLUSION:

The Court held that the district court properly dismissed the petitioner’s action because she failed to include, as required by Fed. R. Civ. P. 8(a)(2), adequate factual allegations to support a claim that the Maryland Department of Transportation's State Highway Administration discriminated against her on the ground that she was African American or female in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. § 2000e-2(a)(1). Moreover, while the employee did allege that the Highway Administration failed to hire her, she did not allege facts sufficient to claim that the reason it failed to hire her was because of her race or sex. In light of these circumstances, the Court ruled that the petitioner’s complaint left open to speculation the cause for the Administration's decision to select someone other than her.

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