Background

• Alivia Blount (Plaintiff), a Nashville resident, sued her former employer, Flemmings Nashville, alleging discrimination under Title VII and the Americans with Disabilities Act (ADA) after being terminated when she returned from medical leave for a documented disability.
• Blount filed the lawsuit pro se and was granted in forma pauperis status by the court.
• The court is obligated to screen in forma pauperis actions, dismissing those that are frivolous, fail to state a claim, or seek relief from immune defendants.
• Filing employment discrimination suits under Title VII and ADA requires prior exhaustion of administrative remedies with the EEOC or a state agency and receipt of a right-to-sue letter.
• The complaint did not allege that Blount filed an EEOC or state agency charge or received a right-to-sue letter, and she failed to comply with a court order to submit such evidence by the deadline.
• The court, finding no evidence of administrative exhaustion despite an opportunity to cure, dismissed the suit without prejudice.

Issues

Key Cases Cited

• Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards for stating a plausible claim)
• Bell Atl. Corp. v. Twombly, 550 U.S. 544 (complaint must state more than unsupported legal conclusions)
• Estelle v. Gamble, 429 U.S. 97 (liberal construction of pro se pleadings)
• Erickson v. Pardus, 551 U.S. 89 (same, pro se pleadings held to less stringent standards)
• Williams v. Curtin, 631 F.3d 380 (evaluating plausibility of claims on initial review)
• Hill v. Lappin, 630 F.3d 468 (standards for dismissal under 28 U.S.C. § 1915)
• Amini v. Oberlin Coll., 259 F.3d 493 (requirement to exhaust administrative remedies before Title VII suit)
• Randolph v. Ohio Dep’t of Youth Servs., 453 F.3d 724 (purpose of administrative exhaustion before federal suit)
• Puckett v. Tenn. Eastman Co., 889 F.2d 1481 (requirements for administrative exhaustion in employment discrimination cases)