Taylor v. Shore
8:11-cv-02137
M.D. Fla.Jul 30, 2012Background
- Taylor, an African American woman, sued Shore, Clerk of the Circuit Court, Manatee County, alleging racial discrimination in termination after twelve years of employment.
- Plaintiff asserted violation of Title VII of the Civil Rights Act and the Florida Civil Rights Act based on unequal treatment for a similar offense.
- Taylor was discharged February 27, 2009, for an alleged failure to record data requested by a client; she contends unwritten policies were not applied to non-Black employees.
- EEOC investigated and issued a February 25, 2011 Letter of Determination finding reasonable cause to believe violations occurred and then referred the matter to DOJ.
- DOJ issued a Right to Sue letter on June 16, 2011, enabling suit; Taylor filed the instant complaint thereafter.
- Defendant moved to dismiss under Rule 12(b)(6); the court denied the motion, allowing Taylor to proceed and requiring an answer within ten days.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether plaintiff states a Title VII/Florida CRA discrimination claim | Taylor's termination and selective enforcement support race-based discrimination. | Complaint lacks factual specificity to plead a prima facie case beyond legal conclusions. | Motion to dismiss denied; claim found plausibly stated. |
| Whether exhibits attached to the complaint can be considered part of the pleadings | EEOC charge, determination, and DOJ letters supply factual basis. | Exhibits are not part of the pleadings to cure pleading deficiencies. | Exhibits properly considered; they provide the factual predicate for the claims. |
| Whether the complaint meets Rule 8 plausibility standard | Exhibits supplement the complaint to show plausible entitlement to relief. | Without detailed factual allegations, the complaint fails under Twombly/Iqbal. | Court finds the combined pleading and attached exhibits plausibly state claims. |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must state plausible claim, not mere conclusory allegations)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard requires factual content showing plausibility)
- American Dental Ass'n v. Cigna Corp., 605 F.3d 1283 (11th Cir. 2010) (plausibility standard governs complaint sufficiency)
- Crawford v. Carroll, 529 F.3d 961 (11th Cir. 2008) (prima facie disparate treatment framework)
- Jordan v. Miami-Dade County, 439 F. Supp. 2d 1237 (S.D. Fla. 2006) (exhibits may be treated as part of pleadings for Rule 12(b)(6) purposes)