911 F. Supp. 2d 373
M.D. La.2012Background
- Plaintiff Edwina Fields, a black female sergeant at Elayn Hunt Correctional Center, has worked for LDPSC since 1999 and alleges age, race, and disability discrimination under Title VII, ADEA, and ADA (and retaliatory FMLA claims).
- Plaintiff also alleges she faced ongoing discriminatory conditions, including assignment to a stressful cell block and denial of accommodations after taking FMLA leave around December 31, 2008.
- Plaintiff claims retaliation for FMLA leave, denial of recognition/awards for responding to an inmate’s hanging attempt, and age discrimination in a job transfer denial.
- EEOC issued a right-to-sue letter, and Plaintiff filed suit on February 23, 2011; Defendant moved to dismiss under Fed. R. Civ. P. 12(b)(1) and 12(b)(6).
- Court addressing subject-matter jurisdiction first, then merits, and ultimately granted in part and denied in part the defense’s motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eleventh Amendment immunity and arm-of-state status | Fields argues federal question jurisdiction and funding negate immunity | LDPSC is an arm of the state with Eleventh Amendment immunity | LDPSC is an arm of the state; Eleventh Amendment immunity applies; ADEA claims dismissed for lack of jurisdiction |
| ADA Title I abrogation and jurisdiction | ADA Title I claims are viable against states | Congress did not validly abrogate state immunity under Title I | Title I ADA claims dismissed for lack of subject-matter jurisdiction |
| FMLA self-care provision abrogation | FMLA self-care provision abrogates immunity allowing suit | Self-care provision does not satisfy congruence and proportionality | FMLA self-care claims dismissed for lack of jurisdiction |
| Title VII abrogation and jurisdiction | Title VII abrogates state immunity and permits suit | Title VII provides no basis for jurisdiction against LDPSC | Court has subject-matter jurisdiction over Title VII claims; proceed on merits |
Key Cases Cited
- Pennhurst State Sch. & Hosp. v. Halderman, 465 U.S. 89 (1984) (sovereign immunity prohibits suits unless waivers or valid abrogation)
- Edelman v. Jordan, 415 U.S. 651 (1974) (Eleventh Amendment immunity applies to state entities)
- Kimel v. Florida Bd. of Regents, 528 U.S. 62 (2000) (ADEA abrogation not valid under Seminole Tribe test)
- Seminole Tribe of Florida v. Florida, 517 U.S. 44 (1996) (two-prong test for congressional abrogation under §5)
- Hibbs v. Department of Human Resources, 538 U.S. 721 (2003) (FMLA abrogation analysis under Seminole Tribe)
- Bd. of Trustees of Univ. of Alabama v. Garrett, 531 U.S. 356 (2001) (ADA Title I claims against states barred without valid abrogation)
- Atascadero State Hospital v. Scanlon, 473 U.S. 234 (1985) (clear declaration or affirmative waiver required for immunity waiver)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (Presents framework for prima facie disparate treatment)
- Kazmier v. Widmann, 225 F.3d 519 (2000) (discrimination remedies under §5 require congruence and proportionality)
- Ga. v. Hibbs, 538 U.S. 721 (2003) (congressionally enacting self-care provision analyzed under §5)