Robert Eagle v. Eastern W. Va. Community and Technical College, etc.
16-0093
| W. Va. | Mar 24, 2017Background
- Eagle, an employee of Eastern West Virginia Community and Technical College, sued the college and its president, Dr. Charles Terrell, alleging retaliation and a hostile work environment under the West Virginia Human Rights Act after he testified in a separate employee’s discrimination trial.
- Eagle’s amended complaint alleged discipline, threats, and escalated harassment after his testimony, and that the hostile environment forced him to leave employment.
- Respondents moved to dismiss under Rule 12(b)(6); the circuit court granted the motions in January 2016, finding (1) some claims based on 2012 events were time-barred, and (2) the timely allegations were only generalized workplace grievances, not actionable discrimination.
- The circuit court also found Dr. Terrell immune, but concluded immunity need not be resolved because the acts alleged did not state valid discrimination claims.
- Eagle appealed, arguing the trial court applied the wrong standard (weighing likelihood of success) and improperly dismissed viable Act claims; the Supreme Court of Appeals affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Statute of limitations for 2012 events | Eagle contends relevant claims are actionable | Eastern/ Terrell argue 2012 events are time-barred | Court: 2012 events are barred by the applicable statute of limitations |
| Sufficiency to state retaliation/discrimination claim | Eagle: pleadings allege adverse actions and retaliation for protected testimony | Respondents: allegations are vague workplace grievances, not adverse actions or causally linked to protected activity | Court: Plaintiff failed to plead a prima facie case; allegations do not amount to actionable discrimination/retaliation |
| Standard for Rule 12(b)(6) dismissal | Eagle: trial court applied improper standard (weighed likelihood of success) and dismissed prematurely | Respondents: dismissal proper because no set of facts would entitle relief | Court: affirmed — trial court applied correct standard in concluding no set of facts would entitle Eagle to relief beyond doubt |
| Immunity of Dr. Terrell | Eagle: individual liability alleged despite immunity defenses | Terrell: immune from suit | Court: immunity issue unnecessary to resolve because alleged acts fail to state a claim |
Key Cases Cited
- McGraw v. Scott Runyan Pontiac-Buick, Inc., 194 W.Va. 770, 461 S.E.2d 516 (1995) (appellate review of Rule 12(b)(6) dismissal is de novo)
- Chapman v. Kane Transfer Co., 160 W.Va. 530, 236 S.E.2d 207 (1977) (complaint should not be dismissed under Rule 12(b)(6) unless no set of facts could entitle plaintiff to relief)
- Conaway v. Eastern Associated Coal Corp., 178 W.Va. 164, 358 S.E.2d 423 (1986) (elements of prima facie employment discrimination)
- Brown v. City of Montgomery, 233 W.Va. 119, 755 S.E.2d 653 (2014) (pleading sufficiency principles and Rule 12(b)(6) standards)