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Federal Court Denies College’s Motion to Dismiss Georgia Woman’s Employment Discrimination Lawsuit

In an Atlanta employment discrimination case, the burden of proof rests on the plaintiff. In order to succeed at trial, the plaintiff must be able to prove each and every element of his or her case. Of course, the defendant in such a case is often quick to seek dismissal of the plaintiff’s lawsuit, sometimes before the discovery process has even begun. In some situations, dismissal of a particular complaint is warranted, but, more often, it is not.

Facts of the Case

In a recent employment discrimination case filed in federal court, the plaintiff was an African-American woman who began working for the defendant college in 2017. According to the plaintiff’s complaint, she was bullied at work and subjected to a hostile work environment. Approximately six weeks after she began her employment, the defendant terminated the plaintiff, allegedly verbally telling her that she was “just not a good fit” and then mailing her a letter stating that her discharge was due to her “failure to perform job duties as assigned.”

Thereafter, the plaintiff filed a charge with the Equal Employment Opportunity Commission, asserting claims of race discrimination, retaliation, bullying, and harassment by a co-worker. Presumably after that proceeding had been completed, the plaintiff filed suit against the defendant in federal court, asserting similar claims. The defendant filed a motion to dismiss the plaintiff’s complaint.

The Court’s Decision

The United States District Court for the Middle District of Georgia, Macon Division, denied the defendant’s motion to dismiss. The court began its analysis by recounting that all that was necessary to defeat a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) was sufficient factual matter to state a claim for relief that was “plausible on its face.” At this stage of litigation, a court was to accept all well-pleaded facts as true and even go so far as to construe any reasonable inferences therefrom in the light that was the most favorable to the plaintiff.

When so construed, the court found that the plaintiff’s complaint contained three claims under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e-2, and 42 U.S.C. § 1981: race discrimination; retaliation; and hostile work environment. The defendant argued that the plaintiff’s complaint should be dismissed because it failed to allege a prima facie case for her claims; however, as the court pointed out, a “prima facie case” was not the correct standard. Under prior case, law, the prima facie case was an evidentiary standard, not a pleading requirement. According to the court, the correct inquiry in the context of a motion to dismiss was whether the plaintiff’s complaint provided enough factual matter (when taken as true) to suggest discrimination, retaliation, or hostile work environment based on her race. Given that the defendant relied on the wrong standard, the court was not inclined to grant the defendant’s motion to dismiss. When accepted as true and construed liberally in the light most favorable to the plaintiff, the allegations contained in the plaintiff’s complaint suggested that she experienced discrimination, retaliation, and harassment due to her race.

Hire an Atlanta Employment Law Attorney

If you need to talk to an experienced Atlanta employment discrimination attorney, please call Attorney John L. Mays at Parks, Chesin & Walbert. Our number is 877-986-5529, and our offices are located at 75 14th Street in Atlanta. We look forward to having the opportunity to serve your legal needs as you seek justice against a former, potential, or current employer.