Cadet v. Overlake Hospital Medical Center, 2:24-cv-01452

Annette Cadet, a Black female dishwasher, sued Overlake Hospital Medical Center (Overlake) pro se, alleging workplace discrimination and harassment under Title VII based on sex, race, and perceived disability.
She claimed coworkers engaged in racially and sexually charged comments, and that management failed to provide appropriate training or address the alleged misconduct.
Cadet sought $200,000 in damages for emotional distress and economic harm.
Overlake moved to dismiss, arguing Cadet failed to properly serve process and did not state sufficient facts to support any legal claim.
Cadet attempted to serve Overlake herself, delivering only the summons (without the complaint) to the hospital's HR office, in violation of Federal Rules.
The court considered the motion to dismiss, striking an improper surreply from Cadet, and evaluated the complaint’s sufficiency under Rule 12(b)(6).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of Service	Service was attempted personally by Cadet with summons to HR.	Service insufficient—only summons served, not complaint, and by improper method.	Service quashed; allowed opportunity to properly serve.
Hostile Work Environment under Title VII	Coworkers’ comments and conduct created an abusive, discriminatory workplace.	Allegations are conclusory, only isolated incidents alleged, not severe or pervasive.	Insufficient facts; claim dismissed with leave to amend.
Discrimination under Title VII	Faced discrimination based on sex, race, and perceived disability.	Lacks facts re: adverse action or disparate treatment, and disability not covered by Title VII.	Insufficient facts; claim dismissed with leave to amend.
Constructive Discharge	Resigned due to intolerable harassment.	No sufficient factual support to meet hostile environment or constructive discharge standards.	Insufficient facts; claim dismissed with leave to amend.

Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard requires more than conclusory statements)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (complaints must set forth sufficient factual matter)
Harris v. Forklift Sys., Inc., 510 U.S. 17 (workplace must be permeated with severe or pervasive discriminatory conduct for Title VII violation)
Bernhardt v. Los Angeles Cnty., 339 F.3d 920 (pro se complaints construed liberally but must meet pleading requirements)
Fed. R. Civ. P. 8(a), 4(c)(1), and 4(h) (Federal Rules governing pleadings and service requirements)