Randy Jones v. Clark County School District
2:15-cv-00010
D. Nev.Mar 31, 2016Background
- Randy Jones was a CCSD school bus driver since 1998 who suffered from anxiety/depressive-related conditions and took prescribed medications.
- In early 2012 his doctor recommended leave; Jones sought alternative CCSD work to avoid FMLA leave but allegedly received none.
- Jones filed an EEOC charge in March 2013 alleging failure to accommodate, forced leave under FMLA, and disability-based mistreatment; he retired May 1, 2013 after exhausting FMLA leave.
- Jones sued CCSD in January 2015 asserting FMLA interference, constructive discharge, intentional infliction of emotional distress (IIED), and seeking punitive damages.
- CCSD moved to dismiss under Rule 12(b)(6), arguing the complaint is conclusory and that punitive damages are unavailable against a Nevada political subdivision.
- The court dismissed the three substantive claims for lacking plausible factual allegations (with leave to amend) and dismissed punitive damages with prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| FMLA interference | CCSD harassed him, refused/ignored FMLA requests, gave "run around," forced him to use sick time | Jones voluntarily retired after exhausting FMLA; allegations are conclusory | Dismissed w/ leave to amend — plead dates, actors, facts to make claim plausible |
| Constructive discharge | CCSD forced him to sign retirement form because no alternative positions existed | Allegations are not factually plausible and do not show intolerable working conditions | Dismissed w/ leave to amend — must allege specific intolerable conditions, dates, actors |
| Intentional infliction of emotional distress | Systematic harassment caused severe emotional distress | Allegations are largely conclusory and lack factual detail | Dismissed w/ leave to amend — plausible facts (extreme conduct, severity, causation) required |
| Punitive damages | Sought punitive relief for alleged misconduct | Punitive damages unavailable against Nevada political subdivisions | Dismissed with prejudice — punitive damages not recoverable against CCSD |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading must be plausible; more than labels and conclusions)
- Ashcroft v. Iqbal, 556 U.S. 662 (two-step test for pleading; reject legal conclusions)
- Poland v. Chertoff, 494 F.3d 1174 (standard for constructive discharge)