Majak v. Starbucks Corporation
2:25-cv-01850
D. Ariz.Jun 3, 2025Background
- Abuk Majak (“Plaintiff”) filed suit against his former employer, Starbucks Corporation (“Defendant”), bringing claims related to discrimination and retaliation.
- Plaintiff sought to proceed in forma pauperis (IFP) due to inability to pay court filing fees without sacrificing life necessities.
- The complaint asserted four causes of action: Title VII racial discrimination, Title VII retaliation, retaliation under the National Labor Relations Act (NLRA), and violation of the Family Medical Leave Act (FMLA).
- The District Court first determined whether Plaintiff qualified for IFP status, then screened the complaint for legal sufficiency as required by 28 U.S.C. § 1915(e)(2).
- The Court also considered its subject matter jurisdiction over the NLRA claim in light of the exclusive jurisdiction of the National Labor Relations Board (NLRB).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether IFP status should be granted | Majak cannot afford filing fees | Not stated | IFP granted |
| Whether complaint states viable claims under Title VII and FMLA | Majak alleges facts supporting discrimination, retaliation, and FMLA violations | Not stated | Counts 1, 2, and 4 may proceed |
| Whether court has jurisdiction over NLRA retaliation claim | Majak asserts NLRA retaliation by Starbucks | Not stated; jurisdictional issue | Dismissed for lack of jurisdiction (NLRB exclusive) |
| Whether to seal personally identifiable information in record | No specific argument | Not stated | Exhibit 2-1 ordered sealed |
Key Cases Cited
- Adkins v. E.I. DuPont de Nemours & Co., 335 U.S. 331 (1948) (sets standard for granting IFP when affiant cannot pay court costs and life's necessities)
- Lopez v. Smith, 203 F.3d 1122 (9th Cir. 2000) (all IFP cases screened under § 1915(e) for failure to state claim)
- Watison v. Carter, 668 F.3d 1108 (9th Cir. 2012) (12(b)(6) standard applies to § 1915(e) screening)
- Wilhelm v. Rotman, 680 F.3d 1113 (9th Cir. 2012) (confirms 12(b)(6) standard in § 1915A screening)
- San Diego Bldg. Trades Council, Millmen’s Union, Local 2020 v. Garmon, 359 U.S. 236 (1959) (Garmon doctrine: NLRB exclusive jurisdiction over certain labor claims)