Haller v. Hobby Lobby Stores, Inc.
1:24-cv-00293
N.D. Ind.Apr 14, 2025Background
- Plaintiffs Ronsard M. Haller and Mary Royse visited a Hobby Lobby store where they saw Christmas stockings arranged to spell a racial slur.
- The display caused the plaintiffs, especially Haller (an African American man), substantial emotional distress, prompting them to report the incident to management.
- The store manager promptly removed the offending display once notified.
- Plaintiffs lost interest in shopping, left the store, and subsequently filed suit, alleging violations of 42 U.S.C. § 1981 and state-law claims for emotional distress.
- The case was removed from state to federal court, and Hobby Lobby moved to dismiss for failure to state a claim.
- The court granted dismissal of the § 1981 claim but denied the motion as to the state-law claims, remanding those to state court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Section 1981 claim: Intentional racial discrimination in contract | Display deprived them of ability to contract due to slur | No facts showing intent to discriminate or denial of contract | Dismissed; insufficient factual support for intent or denial |
| Section 1981 claim: Denial of right to make/enforce contract | Slur constructively evicted them from shopping opportunity | Plaintiffs not denied admittance/service or asked to leave | Dismissed; must show actual loss of contract, not just intent |
| Supplemental jurisdiction over state-law claims | Not directly argued | Not directly argued | Declined to retain; state-law claims remanded to state court |
| Emotional distress state-law claims | Emotional harm from display warrants relief | Not decided on merits in this order | Not addressed; remanded to state court for adjudication |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards for plausibility on a motion to dismiss)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (complaint must nudge claims from conceivable to plausible)
- Pourghoraishi v. Flying J, Inc., 449 F.3d 751 (Section 1981 applies to retail contract rights)
- Morris v. Office Max, Inc., 89 F.3d 411 (Section 1981 requires actual denial of contract rights and intent to discriminate)
- McCauley v. City of Chicago, 671 F.3d 611 (plausibility pleading standard for discrimination claims)