Coleman v. Maryland Court of Appeals, 626 F.3d 187

Coleman, an African-American male, worked for the Maryland Court of Appeals from 2001 to 2007 as executive director of procurement and contract administration.
He was supervised by Frank Broccolina (white) and Faye Gaskins; Larry Jones, a staffer related to Gaskins, was involved in events at issue.
In Oct. 2005, Coleman investigated Jones and Joyce Shue, resulting in a five-day suspension for Jones, later reduced to one day after intervention by Broccolina and Gaskins.
Jones allegedly retaliated by accusing Coleman of steering contracts to favorable vendors; Broccolina shared these false allegations with others.
In April 2007 Coleman received a reprimand for a communication protocol; in Aug. 2007 he sought sick leave for a medical condition and was told he would be terminated if he did not resign.
Coleman asserted Title VII discrimination and FMLA claims; the district court dismissed the Title VII claim for failure to state a claim and dismissed the FMLA claim as barred by Eleventh Amendment immunity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Coleman stated a plausible Title VII race-discrimination claim	Coleman alleges race-based termination and disparate treatment.	Complaint lacks plausibility; no similarly situated white comparator or race-based causal link shown.	Title VII race claim dismissed for lack of plausible facts.
Whether Coleman stated a plausible Title VII retaliation claim	Protected activity (investigation) led to retaliation.	No facts identifying protected activity enough to support retaliation.	Title VII retaliation claim dismissed.
Whether the FMLA claim is barred by Eleventh Amendment immunity	Congress validly abrogated state immunity via the FMLA self-care provision.	Hibbs does not support abrogation of immunity for self-care provision; invalid.	FMLA claim barred; Eleventh Amendment immunity upheld.
Whether Congress validly abrogated state sovereign immunity for the FMLA self-care provision	Self-care provision abrogates immunity under Fourteenth Amendment authority.	Self-care provision not validly abrogating immunity under Hibbs and related precedents.	Congress did not validly abrogate immunity for self-care provision.

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (plausibility standard for pleadings)
Erickson v. Pardus, 551 U.S. 89 (U.S. 2007) (exacting review of complaint allegations in pleadings)
White v. BFI Waste Services, LLC, 375 F.3d 288 (4th Cir. 2004) (framework for Title VII prima facie case elements)
Mackey v. Shalala, 360 F.3d 463 (4th Cir. 2004) (retaliation elements under Title VII)
Nevada Dep't of Human Resources v. Hibbs, 538 U.S. 721 (U.S. 2003) (rehearsal of Fourteenth Amendment abrogation and gender focus)
Bd. of Trs. of Univ. of Alabama v. Garrett, 531 U.S. 356 (U.S. 2001) (Abrogation under Fourteenth Amendment powers)
City of Boerne v. Flores, 521 U.S. 507 (U.S. 1997) (congruence and proportionality in § 5 enforcement power)
Lizzi v. Alexander, 255 F.3d 128 (4th Cir. 2001) (precedent on congressional authority before Hibbs)
Toeller v. Wisconsin Dep't of Corr., 461 F.3d 871 (7th Cir. 2006) (separate analysis of FMLA provisions per Hibbs framework)
Touvell v. Ohio Dep't of Mental Retardation & Developmental Disabilities, 422 F.3d 392 (6th Cir. 2005) (FMLA self-care provision not validly abrogated)
Brockman v. Wyoming Dep't of Family Servs., 342 F.3d 1159 (10th Cir. 2003) (circuit consensus on Hibbs abrogation for self-care)