Lawson v. City of Youngstown, 912 F. Supp. 2d 527

Plaintiff Sheila Lawson sued the Youngstown Municipal Court (YMC) and other state actors for Title VII, OCRA, and related claims.
YMC moved to dismiss under Rule 12(b)(6) and the Court granted, unopposed.
The case was referred to a magistrate, with a later reconsideration deadline set.
Lawson filed a motion for reconsideration (ECF No. 81), which the Court granted in part but left the dismissal of YMC intact.
The Court analyzes whether Ohio law or federal statutes authorize suit against a court, and whether reconsideration is appropriate.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Title VII provides express statutory authority to sue a court.	Lawson argues Title VII includes courts as employers.	YMC argues Title VII cannot authorize suit against a court under Ohio law.	Title VII does not authorize suing a court.
Whether OCRA provides express statutory authority to sue a court.	Lawson contends OCRA defines employer to include courts.	YMC contends OCRA does not expressly authorize suing courts.	OCRA does not clearly authorize suit against a court.
Whether a municipal court is sui juris under Ohio law to be sued.	Lawson relies on statutory definitions to argue sui juris status.	Ohio law generally holds courts are not sui juris absent express authority.	YMC is not sui juris; must be dismissed.
Whether reconsideration should modify the prior dismissal order.	Reconsideration is warranted to correct error.	No new controlling law or evidence; standard warrants no change.	Reconsideration granted but previous dismissal remains.”},{

Malone v. Court of Common Pleas of Cuyahoga County, 45 Ohio St.2d 245, 344 N.E.2d 126 (Ohio 1976) (state courts are not sui juris absent statutory authority)
Mumford v. Basinski, 105 F.3d 264 (6th Cir. 1997) (Eleventh Amendment immunity in §1983 context remains complex)
Kovacevich v. Kent State University, 224 F.3d 806 (6th Cir. 2000) (Congressional abrogation of state immunity varies by statute)
Alkire v. Irving, 330 F.3d 802 (6th Cir. 2003) (multiple factors in determining court immunity in §1983)