Addison v. UPS United Parcel Service
1:24-cv-03183
D. MarylandJul 7, 2025Background
- Plaintiff Morgan Addison, proceeding pro se, filed a civil suit against her former employer United Parcel Service (UPS) and supervisor Jeff Dinger.
- Addison alleges she was assaulted by an unknown person at work on June 18, 2024, leading to her being criminally charged and terminated from employment.
- The complaint claims damages including unlawful termination, medical bills, lost wages, workers’ compensation, and emotional distress.
- The case was initially filed in Maryland state court and then removed to federal court by the defendants.
- Defendants moved for a more definite statement, arguing Addison's claims were too vague for response.
- The court considered Addison's pro se status but found her complaint insufficiently clear regarding specific legal claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Vague pleading/statement of claims | Addison alleges various harms but does not specify legal causes of action | Defendants cannot prepare a response due to lack of clear claims | Motion for more definite statement granted |
| Clarity required under FRCP 8 and 12(e) | Attempts to add facts in response but not specific claims | Argues complaint fails to identify distinct counts or legal bases | Plaintiff must amend complaint |
| Liberal construction for pro se litigant | Relies on the court to interpret claims | Cites duty of plaintiff to plead plausible, clear claims | Liberal construction applied but insufficient |
| Opportunity to amend | N/A | Requests order requiring more definite statement or dismissal | Plaintiff given 21 days to amend |
Key Cases Cited
- Erickson v. Pardus, 551 U.S. 89 (2007) (courts must liberally construe pro se pleadings but not act as advocate)
- Estelle v. Gamble, 429 U.S. 97 (1976) (liberal construction of pro se complaints required)
- Beaudett v. City of Hampton, 775 F.2d 1274 (4th Cir. 1985) (court cannot conjure legal claims for pro se litigant)
- Wall v. Rasnick, 42 F.4th 214 (4th Cir. 2022) (liberal construction can overlook formal deficiencies)
