Rega v. Vanguard Integrity Professionals, Inc., 2:17-cv-00110

Plaintiff Barbara J. Rega, proceeding pro se, sought leave to proceed in forma pauperis under 28 U.S.C. § 1915; the application was granted.
The court initially screened the complaint under § 1915(e) and dismissed with leave to amend because the complaint did not allege that EEOC proceedings had concluded.
Plaintiff filed an amended complaint attaching EEOC right-to-sue letters, curing the court’s prior concern.
The amended complaint alleges, among other claims, Title VII retaliation: Rega complained about discriminatory treatment, was thereafter terminated, and contends the termination was retaliatory.
The court applied the standard for pleading a prima facie retaliation claim at the § 1915 screening stage and found the amended complaint sufficiently pleaded retaliation.
The court ordered the clerk to issue summonses and directed service by the U.S. Marshal, with timelines for Plaintiff to provide USM-285 forms and to report service status; Rule 4(m) 90-day service deadline applies.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the amended complaint states a prima facie Title VII retaliation claim	Rega alleges she engaged in protected activity (complained of discrimination), was terminated, and that termination was retaliatory	Defendants previously contended the complaint failed because EEOC proceedings had not concluded; may also challenge sufficiency of facts	Court held the amended complaint sufficiently pleads retaliation and declined further screening on other claims; permitted service to proceed

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishes burden-shifting framework for prima facie discrimination/retaliation claims)
Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53 (defines actionable retaliation and adverse employment action in Title VII context)