Adams v. Select Quote, Inc.
2:23-cv-11399
| E.D. Mich. | Mar 29, 2025Background
- Jessica Adams sued Select Quote, Inc. alleging violations of the Americans with Disabilities Act (ADA), the Michigan Persons with Disabilities Civil Rights Act (PWDCRA), and the Fair Labor Standards Act (FLSA).
- Adams claimed disability discrimination, retaliation relating to her mental health diagnoses, failure to pay minimum wage and overtime, and retaliation under the FLSA.
- Adams worked at Select Quote from November 2021 to May 2022, experiencing changes in promised compensation, denial of breaks, and pressure to work unpaid overtime.
- After Adams resigned, she filed charges with the EEOC, received a right to sue letter, and then filed the present suit. Select Quote never responded to the complaint, leading to an entry of default.
- Adams moved for default judgment, seeking economic and non-economic damages, attorneys’ fees, and costs; the court held a hearing and considered her renewed motion and certification of damages.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Disability discrimination (ADA/PWDCRA) | Diagnosis of anxiety and depression qualifies | None (defaulted) | DENIED – Allegations do not sufficiently plead a |
| as a disability. | qualifying disability under ADA/PWDCRA. | ||
| Disability-based retaliation (ADA/PWDCRA) | Retaliated against for protected activity, | None (defaulted) | DENIED – No sufficient facts to show adverse action |
| including requesting accommodations. | causally related to protected activity. | ||
| Minimum wage and overtime (FLSA) | Not paid required minimum wage or overtime. | None (defaulted) | GRANTED IN PART – Overtime claim supported; minimum |
| wage claim not supported by facts. | |||
| FLSA retaliation | Retaliated against for complaining about pay. | None (defaulted) | DENIED – Lacks causal connection between complaint |
| and constructive discharge. |
Key Cases Cited
- Shepard Claims Serv., Inc. v. William Darrah & Assocs., 796 F.2d 190 (6th Cir. 1986) (procedure for entry of default judgment under Rule 55)
- Thomas v. Miller, 489 F.3d 293 (6th Cir. 2007) (effect of default on admissions)
- Antoine v. Atlas Turner, Inc., 66 F.3d 105 (6th Cir. 1995) (distinguishing between liability and damages after default)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden-shifting framework for discrimination)
- Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53 (2006) (adverse employment action standard for retaliation)