Brown v. Brickyard Healthcare Fountainview Care Center, 3:23-cv-01020

Heidi Brown, proceeding without a lawyer, brought suit against her former employer, Brickyard Healthcare Fountainview Care Center, alleging employment discrimination under Title VII and referencing HIPAA, OSHA, and other workplace issues.
Brown had multiple complaints dismissed for deficiencies and was given opportunities to amend her complaint, ultimately filing a second amended complaint.
Brown’s employment was terminated in August 2023 after alleged workplace conflicts, unsatisfactory background check completion, and disputed disciplinary actions.
Brown filed charges with local and federal agencies but did not include an EEOC right-to-sue letter with her federal complaint.
After Brickyard moved to dismiss for failure to state a claim, Brown made several additional filings but missed her response deadline and repeatedly failed to cure her pleading defects.
The court granted the defendant’s motion to dismiss and dismissed the case with prejudice after determining the claims could not proceed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Title VII claim—administrative exhaustion	Brown was discriminated against and retaliated	Brown did not allege/produce right-to-sue letter	Dismissed: No exhaustion of EEOC process
HIPAA violation	Brown alleges privacy and data violations	No private right to sue under HIPAA	Dismissed: No private cause of action
OSHA violation	Brown alleges workplace safety violations	No private right to sue under OSHA	Dismissed: No private cause of action
Other claims (blacklisting, hate crime, etc.)	Brown lists multiple grievances and rights violated	No facts pleaded, only conclusory allegations	Dismissed: Insufficient factual allegations

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (sets pleading standard for plausibility of claims)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (articulates standard for pleading sufficient factual matter)
Alexander v. Gardner-Denver Co., 415 U.S. 36 (1974) (plaintiff must exhaust administrative remedies before suit under Title VII)
Cheek v. W. & S. Life Ins. Co., 31 F.3d 497 (7th Cir. 1994) (plaintiff cannot bring claims not included in EEOC charge)
Fort Bend Cnty. v. Davis, 139 S. Ct. 1843 (2019) (discusses Title VII’s administrative requirements for suit)
Reynolds v. CB Sports Bar, Inc., 623 F.3d 1143 (7th Cir. 2010) (standard for motion to dismiss under Rule 12(b)(6))
McCauley v. City of Chicago, 671 F.3d 611 (7th Cir. 2011) (conclusory allegations are not entitled to presumption of truth)
Teal v. Potter, 559 F.3d 687 (7th Cir. 2009) (administrative exhaustion required for Title VII claims)