Cassamajor v. Planet Fitness
8:25-cv-00102
M.D. Fla.Apr 17, 2025Background
- Pro se plaintiff Willys Cassamajor sued Planet Fitness and unnamed employees claiming discrimination during his gym membership in December 2024.
- Allegations included being falsely accused of unpaid bills, denied equal access to services, and being humiliated by staff, resulting in emotional distress and hospitalization.
- Cassamajor filed for in forma pauperis (IFP) status, reporting low income and financial hardship.
- The complaint asserted federal claims under Title II of the Civil Rights Act of 1964 and state law claims for negligence and intentional infliction of emotional distress.
- The motion and complaint were referred to the Magistrate Judge for a report and recommendation on whether Cassamajor could proceed without paying fees and if his complaint was sufficient to proceed.
- The court found pleading deficiencies and substantive problems with the Title II claim, recommending dismissal without prejudice and denial of the IFP motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency under Rules 8 & 10 (Pleading) | Complaint gives sufficient notice and incorporates facts | Pleading is unclear, overbroad | Complaint is an improper shotgun pleading and fails to meet requirements |
| Proper identification of defendants | Defendants sufficiently identified as Planet Fitness and Does | Complaint does not specify who did what | Complaint fails to specify which allegations apply to which defendants |
| Stating a Title II discrimination claim | Denied equal access due to discrimination | Insufficient facts on discrimination | Complaint fails to plead protected class status, exhaustion, or factual support |
| In Forma Pauperis (IFP) qualification | Plaintiff cannot afford fees | No argument recorded | IFP denied without prejudice, pending proper complaint |
Key Cases Cited
- Martinez v. Kristi Kleaners, Inc., 364 F.3d 1305 (11th Cir. 2004) (sets forth standard for indigency under IFP statute)
- Franklin v. Curry, 738 F.3d 1246 (11th Cir. 2013) (explains courts do not accept legal conclusions as true at pleading stage)
- McNeil v. United States, 508 U.S. 106 (1993) (pro se litigants must comply with procedural rules)
- Bryant v. Dupree, 252 F.3d 1161 (11th Cir. 2001) (plaintiffs should be given leave to amend defective complaints)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (standards for pleading plausibility)