Moss v. Board of Education of the Sachem Central School District, 2:22-cv-06212

Plaintiff William King Moss III, a Black male and former teacher and administrator, applied for a K-8 principal position at Hiawatha Elementary School in the Sachem Central School District.
Despite meeting the basic qualifications, Plaintiff was not selected for a screening interview or hired; the position went to Joseph Watson, a white male with assistant principal experience.
Plaintiff filed complaints in state and federal court, alleging race discrimination and conspiracy in violation of Title VII, Sections 1981, 1983, and 1985.
Plaintiff’s state cases were dismissed, and he then pursued nearly identical claims in federal court after receiving a right-to-sue letter from the EEOC.
Defendants moved to dismiss the federal complaint under Rule 12(b)(6), arguing Plaintiff failed to plausibly allege discrimination or conspiracy.
The Court ultimately granted the motion to dismiss, concluding Plaintiff’s claims were unsupported by sufficient factual allegations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Failure to hire based on race (Title VII/§1983)	Plaintiff was more qualified than those interviewed/hired; race was the reason	Plaintiff lacked required Principal/Assistant Principal experience; race not a factor	Dismissed: Plaintiff failed to plausibly allege discriminatory motive
Disparate treatment/disparate impact	Plaintiff was not interviewed while less qualified, non-Black candidates were	No evidence that race was causally connected; comparators not similarly situated	Dismissed: No inference of discrimination or disparate impact
Conspiracy under §1985	Defendants conspired to deny Plaintiff an interview based on race	No factual basis for agreement or discriminatory intent; barred by intra-corporate doctrine	Dismissed: No plausible factual basis, intra-corporate doctrine bars claim
Personal involvement of individual defendants	Each individual should be liable for the decision	No specific personal involvement alleged for most, many not in decision-making roles	Dismissed: No personal involvement plausibly alleged

Ashcroft v. Iqbal, 556 U.S. 662 (plausibility pleading standard for Rule 12(b)(6))
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (complaint must state a plausible claim for relief)
Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (no respondeat superior municipal liability under §1983)
Griggs v. Duke Power Co., 401 U.S. 424 (disparate impact employment discrimination standard)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for employment discrimination)
Erickson v. Pardus, 551 U.S. 89 (pro se pleadings held to less stringent standards)
Segal v. City of N.Y., 459 F.3d 207 (municipal liability claims require underlying constitutional violation)