Hobbs v. Cobb
Civil Action No. 2022-1076
| D.D.C. | May 6, 2022Background
- Plaintiff Lawrence Hobbs, proceeding pro se, sued an EEOC Administrative Law Judge (ALJ), the EEOC, and unnamed EEOC employees, alleging the ALJ deprived him of constitutional rights by delaying resolution of his employment-discrimination matter and failing to rule on his motions for sanctions.
- All alleged harms arose from actions taken in the course of the EEOC administrative proceedings.
- The Court considered Hobbs’s application to proceed in forma pauperis.
- The Court concluded ALJs are entitled to absolute judicial immunity for actions taken in their official adjudicative role.
- The Court also concluded Congress has not authorized private suits against the EEOC for how it processes discrimination charges.
- The Court granted IFP status but dismissed the complaint for failure to state a claim under 28 U.S.C. § 1915(e)(2)(B)(ii).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Immunity of EEOC ALJ | ALJ’s delays and failure to rule deprived Hobbs of constitutional rights | ALJ is entitled to absolute judicial immunity for actions in official adjudicative capacity | Dismissed: ALJ enjoys absolute immunity; claims barred |
| Suitability of claims against the EEOC and employees | EEOC and employees negligently/malfeasantly processed Hobbs’s charge | Title VII does not create an express or implied cause of action against the EEOC for processing charges | Dismissed: Congress did not authorize suits against the EEOC for charge processing |
| Proceeding in forma pauperis and screening of complaint | Hobbs sought IFP and to proceed with claims | Court must screen IFP complaints under §1915(e)(2)(B) | IFP granted; complaint dismissed for failure to state a claim |
Key Cases Cited
- Butz v. Economou, 438 U.S. 478 (1978) (extending judicial immunity to federal administrative judges)
- Smith v. Casellas, 119 F.3d 33 (D.C. Cir. 1997) (no express or implied cause of action against the EEOC for processing charges)
- McCottrell v. Equal Employment Opportunity Comm’n, 726 F.2d 350 (7th Cir. 1984) (Title VII does not authorize suits against the EEOC for its investigation or processing of a charge)
- Brown v. Berrein, 923 F. Supp. 2d 43 (D.D.C. 2013) (dismissing suit against the EEOC for dismissing a charge as untimely)