Harris v. American Airlines, Inc., 3:17-cv-00280

Plaintiff LaTanya Harris filed an EEOC charge on April 6, 2016 alleging race, age, disability discrimination and retaliation, and received a right-to-sue notice on January 25, 2017.
Harris filed this suit on May 12, 2017 asserting claims under Title VII, 42 U.S.C. § 1981, the ADEA, the ADA, and the FMLA against American Airlines.
Defendant removed the case to federal court and moved to dismiss under Rule 12(b)(6).
The court applied the Twombly/Iqbal plausibility standard to the complaint.
The court addressed administrative-exhaustion/timeliness requirements for Title VII, ADEA, and ADA claims (180-day filing rule) and identified October 9, 2015 as the cutoff date (180 days before April 6, 2016).
Plaintiff conceded that failure to exhaust/time-barred claims was fatal to many claims arising before that cutoff.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Title VII, ADEA, and ADA claims based on conduct before Oct. 9, 2015 are barred for failure to exhaust the EEOC 180-day filing requirement	Harris did not contest that many pre-Oct. 9, 2015 claims are untimely; no viable contrary argument presented	Such claims are time-barred because the EEOC charge was filed April 6, 2016, so acts before Oct. 9, 2015 fall outside the 180-day window	Court granted the motion and dismissed all Title VII, ADEA, and ADA claims arising before Oct. 9, 2015

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must state a plausible claim to survive a Rule 12(b)(6) motion)
Bell Atl. Corp. v. Twombly, 550 U.S. 554 (2007) (established the plausibility standard for complaints)
Jones v. Calvert Group, Ltd., 551 F.3d 297 (4th Cir. 2009) (failure to file an EEOC charge within the statutory period bars suit under Title VII/ADEA)
Sydnor v. Fairfax County, Va., 681 F.3d 591 (4th Cir. 2012) (failure to exhaust administrative remedies bars ADA claims)