Greggs v. Autism Speaks, Inc.
935 F. Supp. 2d 9
D.D.C.2013Background
- Greggs, a 44-year-old Maryland resident with an autistic child, sues Autism Speaks and several individuals seeking relief for alleged discriminatory employment practices and a breached job offer.
- She applied for the Walk Events Manager position at Autism Speaks in March 2012 and progressed through multiple interviews culminating in an April 13, 2012 offer.
- The offer was contingent on passing a background check and drug test, which Greggs reportedly did, with a May 7, 2012 start date set.
- On May 6, 2012, Greggs raised a daycare concern; Autism Speaks allowed a one-week delay but later rescinded the offer on May 7, 2012, stating no accommodations would be made for her autistic child.
- Greggs filed an EEOC complaint on May 8, 2012 and filed this federal suit on July 6, 2012; defendants moved to dismiss on July 30, 2012.
- The court granted the motion to dismiss, concluding the complaint failed to state viable Title VII/§1981/ADA claims, failed to exhaust administrative remedies, and stated no viable breach-of-contract claim against any defendant.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Title VII/§1981 claims are viable | Greggs alleges discrimination based on her disabled child, not her race/sex/religion, seeking Title VII relief. | Plaintiff's allegations do not plead race/color/religion/national origin discrimination and lack plausible facts under Title VII/§1981. | Dismissed Title VII/§1981 claims for lack of plausible pleading. |
| Whether ADA/Title VII claims were exhausted administratively | EEOC filing and investigation were ongoing; action timely after exhaustion window. | Plaintiff filed suit before 180 days and before a right-to-sue letter, failing to exhaust. | Dismissed ADA/Title VII claims for failure to exhaust administrative remedies. |
| Whether there is a viable breach of contract claim | Offer letter constituted a contract and its rescission breached it; failure to honor terms. | Offer was at-will and not a contractual term altering at-will status; individual defendants were not parties. | Dismissed breach-of-contract claims against individuals and Autism Speaks; no viable contract claim. |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (pleading standard requires plausible claims)
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (plausibility standard for pleading)
- Kowal v. MCI Commc'ns Corp., 16 F.3d 1271 (D.C. Cir. 1994) (court may reject implausible inferences in pleading)
- Domino's Pizza, Inc. v. McDonald, 546 U.S. 470 (U.S. 2006) (Section 1981 discrimination claim arising from contractual breach)
- Park v. Howard Univ., 71 F.3d 904 (D.C. Cir. 1995) (administrative exhaustion requirement for Title VII/ADA claims)
- Dahlman v. Am. Ass'n of Retired Persons (AARP), 791 F. Supp. 2d 68 (D.D.C. 2011) (administrative exhaustion generally required before suit)
- Wilson v. Pena, 79 F.3d 154 (D.C. Cir. 1996) (purpose of exhaustion doctrine in Title VII/ADA context)
- Turner v. Fed. Express Corp., 539 F. Supp. 2d 404 (D.D.C. 2008) (at-will employment presumption in DC law)
- Daisley v. Riggs Bank, N.A., 372 F. Supp. 2d 61 (D.D.C. 2005) (termination of at-will employment does not breach contract)