Edoho-Eket v. RH, Restoration Hardware Inc., 3:18-cv-01327

Pro se plaintiff filed suit alleging employment discrimination (harassment, sexual harassment, hostile work environment, retaliation) arising from employment at Restoration Hardware from June 11, 2018 to July 19, 2018, and alleged housing discrimination (evictions, threats) at multiple properties managed by Lincoln Property Management during 2016–2018.
Plaintiff asserted violations of Title VII (employment) and the Fair Housing Act (FHA) and sought large damages; pleadings contained largely conclusory allegations with few factual details beyond dates and general labels of misconduct.
Restoration Hardware and Lincoln each moved to dismiss under Fed. R. Civ. P. 12(b)(6) for failure to state a plausible claim; plaintiff did not respond to the motions.
The magistrate judge applied the Twombly/Iqbal plausibility standard and pro se pleading principles, but noted pro se plaintiffs remain bound by Rule 8 and must plead sufficient facts.
The magistrate recommended both motions to dismiss be GRANTED because the complaint lacked factual allegations supporting Title VII or FHA claims against the respective defendants.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plaintiff stated a plausible Title VII hostile-work-environment/retaliation claim against Restoration Hardware	Plaintiff alleges she endured harassment, sexual harassment, hostile environment, and retaliation leading to wrongful termination	Restoration Hardware: complaint contains only conclusory labels and the employment dates; no factual allegations to show harassment, sex-based discrimination, protected activity, or causal link	Dismissal recommended — plaintiff failed to plead facts making Title VII claims plausible
Whether plaintiff stated a plausible FHA discrimination/interference claim against Lincoln Property Management	Plaintiff alleges repeated threats to vacate and evictions she believes were tied to trafficking, harassment, extortion, and slavery; alleges FHA violation	Lincoln: plaintiff must plead discriminatory intent or facts giving rise to inference of discrimination; vague conclusions insufficient	Dismissal recommended — complaint lacks factual predicate to infer discriminatory purpose under FHA
Applicability of pleading standards to a pro se litigant	Plaintiff relies on pro se status and broad allegations of abuse and discrimination	Defendants: Rule 8 and Twombly/Iqbal require factual allegations; pro se status lowers but does not eliminate pleading requirements	Court: pro se complaints are liberally construed but must still contain factual allegations; conclusory statements insufficient

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading must state a claim that is plausible on its face)
Ashcroft v. Iqbal, 556 U.S. 662 (legal conclusions not entitled to assumption of truth; plausibility standard)
Meritor Savings Bank FSB v. Vinson, 477 U.S. 57 (Title VII prohibits hostile work environment sexual harassment)
Harris v. Forklift Systems, Inc., 510 U.S. 17 (hostile-work-environment standard)
International Brotherhood of Teamsters v. United States, 431 U.S. 324 (intentional acts with discriminatory purpose required for certain discrimination claims)
Gazette v. City of Pontiac, 41 F.3d 1061 (6th Cir. standard construing complaint in plaintiff's favor)
Randolph v. Ohio Dep't of Youth Servs., 453 F.3d 724 (6th Cir. elements for hostile-work-environment claim)
Singfield v. Akron Metro Hous. Auth., 389 F.3d 555 (6th Cir. elements for retaliation claim)
Graoch Assocs. #33, LP v. Louisville/Jefferson County Metro Human Relations Comm'n, 508 F.3d 366 (FHA jurisprudence parallels Title VII)