Lane v. Commonwealth of Massachusetts Essex County Sheriff's Department
1:24-cv-13091
| D. Mass. | Jun 27, 2025Background
- Plaintiff Craig Gerald Lane alleges the Essex County Sheriff’s Department and representatives discriminated against him by failing to promote him in 2017 and 2019.
- Claims are premised on disability, age, race, and gender discrimination under the ADA, ADEA, and Title VII.
- Lane filed a charge with the EEOC (Charge No. 16C-2021-00211) before initiating this suit, but did not attach the charge or EEOC response to the court filing.
- Defendants moved to dismiss, arguing Lane’s claims are untimely under applicable statutes of limitations.
- Plaintiff did not oppose the motion to dismiss.
- Court found the record insufficient as to whether the claims meet the specific time requirements for filing discrimination suits in federal court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness of ADA, ADEA, Title VII claims | Charge filed with EEOC | Filed too late; time-barred | Not enough info; requires EEOC filings |
| Proper statute of limitations for claims | Not specified by plaintiff | Three years under Mass. law | 300 days for charge; 90 days post-EEOC |
| Title II ADA claim time-bar | Not specified | More than 3 years have passed | Title II barred if over 3 years |
| Evidence/documentation adequacy | EEOC charge filed | Missing documentation | Lane must submit EEOC docs to proceed |
Key Cases Cited
- Vesprini v. Shaw Indus., Inc., 221 F. Supp. 2d 44 (D. Mass. 2002) (timeliness of ADEA discrimination charges under federal law)
- Noviello v. City of Boston, 398 F.3d 76 (1st Cir. 2005) (Title VII timing requirements after EEOC right-to-sue letter)
- Hall v. Minner, 411 Fed. App’x 443 (3d Cir. 2011) (ADA Title II limitations period borrows from state law)