Joanne Kaminski v. Elite Staffing, Inc., 23 F.4th 774

Joanne Kaminski, a Polish‑American woman in her 50s, worked for Elite Staffing (a temp agency) for about 2½ years and had no prior disciplinary record.
In late 2019 a host warehouse told Elite Staffing it no longer needed her, and Elite Staffing terminated her pursuant to a policy of firing employees discharged by a host.
After Elite Staffing declined to give her former coworkers' names, Kaminski (pro se) sued under Title VII and the ADEA alleging discharge because of age, race, and national origin.
The district court screened the second amended complaint under 28 U.S.C. § 1915(e), gave two chances to amend, then dismissed with prejudice for failure to state a claim, reasoning Kaminski had not pleaded a prima facie case (relying on Barricks).
The Seventh Circuit affirmed: Kaminski’s complaint failed Rule 8/Twombly‑Iqbal pleading requirements because it alleged only legal labels (discrimination) without factual allegations plausibly linking the termination to her protected characteristics.
The court cautioned that the district court appeared to apply a summary‑judgment prima facie standard at the pleading stage, which is inappropriate, but the dismissal was nonetheless affirmed on the pleadings ground.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Kaminski pleaded a plausible Title VII/ADEA discrimination claim	Kaminski alleges she was fired because she is over 50, Polish (national origin), and white (race)	Elite Staffing argues the complaint contains no factual nexus between termination and protected traits and lacks comparators	Court: Complaint failed Rule 8/Twombly‑Iqbal; no plausible facts connecting discharge to protected characteristics; dismissal affirmed
Whether the district court applied the correct pleading standard	Kaminski (implicitly) contends her allegations suffice to proceed	District court relied on Barricks and prima facie McDonnell Douglas elements (summary‑judgment framework)	Court: District court seemed to impose a summary‑judgment prima facie requirement at pleading stage—improper—but the dismissal stands because the complaint lacked factual allegations to make discrimination plausible
Treatment of pro se pleadings and need for factual specificity	Kaminski, pro se, sought liberal construction of her allegations	Elite Staffing contended legal labels without factual support cannot survive dismissal	Court: Pro se complaints are construed liberally, but they still must include short, plain, plausible factual allegations showing a "because of" connection; Kaminski’s complaint did not meet that standard

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility pleading standard under Rule 8)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must plead factual content raising claim above speculative level)
Barricks v. Eli Lilly & Co., 481 F.3d 556 (7th Cir. 2007) (discusses McDonnell Douglas prima facie framework in summary judgment context)
Swierkiewicz v. Sorema N.A., 534 U.S. 506 (2002) (plaintiff need not plead full prima facie case to survive pleading stage)
Graham v. Bd. of Educ., 8 F.4th 625 (7th Cir. 2021) (employment discrimination pleading requires plausible link to protected characteristic)
Carlson v. CSX Transp., Inc., 758 F.3d 819 (7th Cir. 2014) (pleading should tell a "story that holds together")
Doe v. Columbia Coll. Chicago, 933 F.3d 849 (7th Cir. 2019) (generalized allegations insufficient; must add facts particular to the case)
Tamayo v. Blagojevich, 526 F.3d 1074 (7th Cir. 2008) (Twombly interpretation in employment context; need fair notice and non‑speculative allegations)
Bell v. City of Chicago, 835 F.3d 736 (7th Cir. 2016) (labels and conclusions are inadequate)
Swanson v. Citibank, N.A., 614 F.3d 400 (7th Cir. 2010) (complaint should present cohesive factual narrative)