Brooks v. Maryland Legal Aid, 1:24-cv-02973

Linda Darnell Brooks, a Black female born in 1967, was employed by Maryland Legal Aid from 1998 and promoted to Human Resources Specialist – Benefits in 2002.
Beginning January 2023, Brooks alleges that Jessica Sysak, Chief Human Resources Officer, harassed her and created a hostile work environment.
In January 2024, Brooks' position was reclassified to Benefits Coordinator with a $26,000 pay cut; she was told to accept the new position with a $5,000 transition payment or face termination.
Brooks declined the new role and was terminated in February 2024; she later returned the transition payment.
Brooks filed a self-represented employment discrimination lawsuit for race, age, and gender discrimination; defendants moved to dismiss under Rule 12(b)(6).
The court, finding the Complaint did not state plausible claims, granted the motion to dismiss without prejudice, allowing Brooks thirty days to amend.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of Discrimination Claim	Brooks was targeted due to her race, age, and gender, leading to adverse employment action.	Adverse action alone, without facts showing discrimination, is insufficient.	Plaintiff failed to allege plausibly discriminatory motive; complaint dismissed.
Individual Liability for Sysak	Sysak liable under state/federal law	No individual liability under federal law.	Federal claims against Sysak as an individual not viable.
Hostile Work Environment	Alleged continuous harassment.	No supporting factual allegations provided.	No facts pled to show harassment based on protected status.
Leave to Amend Complaint	N/A	N/A	Dismissal without prejudice; leave to seek amendment within 30 days.

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (establishes plausibility standard for pleading under Rule 12(b)(6))
Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (clarifies pleading standards for all civil cases, including plausibility)
Swierkiewicz v. Sorema N.A., 534 U.S. 506 (U.S. 2002) (complaints need not allege a prima facie discrimination case to survive dismissal)
Erickson v. Pardus, 551 U.S. 89 (U.S. 2007) (pro se complaints are to be liberally construed)