CHAPMAN v. WOOD, 1:22-cv-02278

Background

Chapman worked as an administrative assistant for Siemens Healthineers (hired Oct. 2017); she refused a COVID-19 vaccine citing religious beliefs and a cancer diagnosis and sought accommodations that were denied.
On Nov. 15, 2021, site director Chris Hamalak escorted Chapman out and placed her on involuntary unpaid leave; Siemens terminated her employment Feb. 11, 2022.
Chapman alleges religious discrimination (Title VII), disability discrimination (ADA), age discrimination (ADEA), and violation of the Indiana Civil Rights Law; she filed administrative complaints and received right-to-sue letters before suing Siemens, Linda Wood (HR partner), and Chris Hamalak.
Defendants moved to dismiss: all defendants moved to dismiss the Indiana Civil Rights Law claim for lack of subject-matter jurisdiction (Fed. R. Civ. P. 12(b)(1)); Wood and Hamalak also moved to dismiss the Title VII, ADA, and ADEA claims against them for failure to state a claim (Fed. R. Civ. P. 12(b)(6)).
Chapman is pro se and did not respond to the individuaI-defendants’ motion; the court treated the jurisdictional challenge to the state-law claim as implicating the availability of relief and converted that portion of the motion to summary judgment, giving Chapman time to submit evidence.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether individual defendants (Wood, Hamalak) may be held liable under Title VII, ADA, and ADEA	Chapman alleges Wood and Hamalak participated in the suspension and firing and included them as defendants	Federal employment statutes impose liability on employers, not individual employees	Dismissed Title VII, ADA, and ADEA claims against Wood and Hamalak; individuals not liable under those statutes
Whether this court lacks jurisdiction to adjudicate Chapman’s Indiana Civil Rights Law claim because the Indiana Civil Rights Commission (ICRC) didn’t find probable cause and the parties didn’t consent to state-court resolution	Chapman proceeded after administrative exhaustion and obtained right-to-sue letters and alleged rights under Indiana law	Defendants point to an ICRC transfer notice to the EEOC as evidence there was no probable cause and no written consent to proceed in state court, so no state-court jurisdiction and no right to relief under Indiana law	State law jurisdictional limits don’t defeat federal-court jurisdiction but can bar substantive relief; the court recast the challenge as a merits/pleading issue and declined to rule without converting to summary judgment and giving Chapman time to submit evidence
Whether the ICRC transfer letter may be considered on a Rule 12(b)(6) motion	Chapman’s complaint referenced administrative filings/right-to-sue letters	Defendants argued the transfer letter is an exhibit referenced in the complaint and central to the claim so can be considered	Court held the transfer letter was not sufficiently referenced/central to treat it as part of the pleadings; conversion to Rule 56 required before considering the letter
Effect of Chapman’s pro se status and failure to respond to the individuaI-defendants’ motion	Chapman is pro se and entitled to liberal construction of pleadings	Defendants noted Chapman did not oppose or explain why individual liability should apply	Court liberally construes pro se pleadings but dismissed the federal statutory claims against the individuals and noted Chapman’s failure to respond undermined any opposition

Key Cases Cited

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard: complaint must state a plausible claim).
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for pleadings).
AnchorBank, FSB v. Hofer, 649 F.3d 610 (7th Cir. 2011) (accept well-pleaded allegations as true on Rule 12(b)(6)).
Alexander v. City of S. Bend, 256 F. Supp. 2d 865 (N.D. Ind. 2003) (distinguishing legal sufficiency and factual sufficiency on 12(b)(6)).
Nischan v. Stratosphere Quality, LLC, 865 F.3d 922 (7th Cir. 2017) (draw reasonable inferences in plaintiff’s favor at pleading stage).
Johnson v. Apna Ghar, Inc., 330 F.3d 999 (7th Cir. 2003) (on 12(b)(1) court may consider evidence beyond pleadings to resolve jurisdiction).
Williams v. Banning, 72 F.3d 552 (7th Cir. 1995) (Title VII and ADA do not impose individual liability).
Horwitz v. Bd. of Educ. of Avoca Sch. Dist. No. 37, 260 F.3d 602 (7th Cir. 2001) (ADEA does not impose individual liability).
M.C. Welding & Machining Co. v. Kotwa, 845 N.E.2d 188 (Ind. Ct. App. 2006) (ICRC administrative enforcement scheme).
Fort Wayne Metro. Hum. Rels. Comm’n v. Marathon Gas Station (Nachhatar Stores, Inc.), 926 N.E.2d 1085 (Ind. Ct. App. 2010) (state trial jurisdiction requires written consent of parties under ICRC scheme).
Zahn v. N. Am. Power & Gas, LLC, 847 F.3d 875 (7th Cir. 2017) (state law cannot curtail federal-court jurisdiction but can deny a state-created right to relief).
Tacket v. Gen. Motors Co., Delco Remy Div., 93 F.3d 332 (7th Cir. 1996) (convert 12(b)(1) jurisdictional challenges into 12(b)(6) when appropriate).
Venture Assocs. Corp. v. Zenith Data Sys. Corp., 987 F.2d 429 (7th Cir. 1993) (documents central to complaint may be considered on a motion to dismiss).
Levenstein v. Salafsky, 164 F.3d 345 (7th Cir. 1998) (must convert to Rule 56 before considering materials outside the pleadings).