McGriff v. Beavercreek City Schools
3:18-cv-00372
| S.D. Ohio | Aug 7, 2019Background
- Plaintiff Bonnie McGriff, a long‑time teacher (since 1996), alleges a hearing impairment (50% hearing deficiency requiring hearing aids) and fibromyalgia; she claims stress from work worsens her conditions.
- For the 2017–2018 school year Beavercreek reassigned McGriff from teaching Spanish (her long‑taught subject) to teaching only French, which she says is harder to teach given her hearing loss.
- McGriff alleges younger and non‑disabled employees received more favorable assignments and that the reassignment exacerbated her medical conditions and caused lost pay/benefits.
- She filed an administrative discrimination charge with the Ohio Civil Rights Commission; after dismissal she sued in federal court alleging age discrimination (ADEA) and disability discrimination (ADA).
- Beavercreek moved to dismiss under Fed. R. Civ. P. 12(b)(6), arguing McGriff failed to meet Twombly/Iqbal pleading standards and failed to allege an adverse employment action or a valid disability.
- The district court denied the motion, finding McGriff pleaded sufficient factual predicates to give Beavercreek fair notice of both claims and noting that a plaintiff need not plead a prima facie case at the pleading stage.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Pleading sufficiency under Twombly/Iqbal | McGriff alleges specific facts: reassignment, comparators, medical aggravation, lost pay/benefits — more than labels | Beavercreek: complaint is conclusory and fails Twombly/Iqbal | Court: complaint satisfies Rule 8; not a mere formulaic recitation; survives 12(b)(6) |
| Adverse employment action (ADEA) | Reassignment caused lost pay/benefits, hostile work environment, medical aggravation — constitutes materially adverse action | Beavercreek: no termination, demotion, pay cut, title change, or diminished responsibilities | Court: allegations (lost benefits/pay, unique harms, medical consequences) suffice at pleading stage; dismissal improper |
| Disability element and adverse action (ADA) | McGriff alleges hearing impairment and fibromyalgia, told employer of medical consequences; claims adverse action from reassignment | Beavercreek: fails to plead a qualifying disability and an adverse employment decision | Court: allegations of impairments and notice to employer put defendant on notice; adverse action sufficiently alleged for pleading purposes |
| Requirement to plead prima facie case at motion to dismiss | Plaintiff: not required to plead full prima facie case; need only provide factual predicate and statutory basis | Defendant: insists prima facie elements must be pleaded now | Court: relies on Swierkiewicz/Lindsay — plaintiff need not establish prima facie case to survive 12(b)(6); summary judgment is the proper vehicle for testing merit |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading must be plausible; labels and conclusions insufficient)
- Ashcroft v. Iqbal, 556 U.S. 662 (legal conclusions must be supported by factual allegations)
- Swierkiewicz v. Sorema, 534 U.S. 506 (plaintiff not required to plead prima facie case to survive Rule 12(b)(6))
- Erickson v. Pardus, 551 U.S. 89 (Rule 8(a) requires only short and plain statement; dismissal improper where complaint gives fair notice)
- Kocsis v. Multi‑Care Mgmt., 97 F.3d 876 (elements and standards for disability discrimination claims)
- Lindsay v. Yates, 198 F.3d 434 (plaintiff must allege statutory basis and factual predicate to pass pleading stage)