Thomas v. School Board of Bienville Parish, 5:22-cv-05867

Thomas, a Bienville Parish School Board teacher during the COVID-19 pandemic, reported medical conditions (diabetes; immune suppression from ankylosing spondylitis medication) and sought to work from home with physician notes.
The School Board denied individual remote-teaching requests, stating it would not permit select teachers to teach from home and citing financial/sub coverage concerns.
The Board had created a virtual academy for remote students and used teachers for that platform; Thomas alleges he was not offered that option.
After unsuccessful attempts to resolve the issue and loss of income, Thomas resigned in March 2022 and filed an EEOC charge; he later received a Right-to-Sue for an ADAAA claim and filed this pro se suit on November 3, 2022 asserting Title VII and ADAAA claims.
The School Board moved to dismiss under Rule 12(b)(6). The court dismissed the Title VII claim with prejudice for failure to exhaust administrative remedies and denied dismissal of the ADAAA failure-to-accommodate claim as plausibly pleaded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Thomas exhausted administrative remedies for a Title VII claim	Thomas filed a pro se complaint form mentioning Title VII but did not allege Title VII facts to the EEOC	School Board: EEOC charge did not raise Title VII; exhaustion not met	Title VII claim dismissed with prejudice for failure to exhaust administrative remedies
Whether Thomas plausibly alleged an ADAAA failure-to-accommodate claim	Thomas: he is disabled, provided physician notes, virtual academy was available and could have allowed him to perform essential functions	School Board: facts insufficient to show a "qualified individual" or a reasonable accommodation	Denied dismissal — complaint plausibly alleges disability, employer knowledge, and failure to provide reasonable accommodation at pleading stage
Appropriate pleading standard and remedy (pro se leniency; prejudice of dismissal)	Thomas (pro se) benefits from liberal construction and lower pleading burden	School Board urged dismissal under Iqbal/Twombly standard	Court applied plausibility standard with pro se leniency and found ADAAA claim survives; Title VII dismissal with prejudice is appropriate because exhaustion can no longer be cured

Gonzalez v. Kay, 577 F.3d 600 (5th Cir. 2009) (pleading standard guidance)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility pleading standard)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for complaints)
Thompson v. Microsoft Corp., 2 F.4th 460 (5th Cir. 2021) (elements of failure-to-accommodate claim)
Moss v. Harris Cty. Constable Precinct One, 851 F.3d 413 (5th Cir. 2017) (ADA elements discussion)
Feist v. Louisiana Dep’t of Justice, Office of the Attorney General, 730 F.3d 450 (5th Cir. 2013) (reasonable accommodation enabling essential functions)
Haines v. Kerner, 404 U.S. 519 (1972) (liberal construction of pro se pleadings)
Taylor v. Books A Million, Inc., 296 F.3d 376 (5th Cir. 2002) (Title VII administrative exhaustion requirement)
Dawson Farms, LLC v. Farm Serv. Agency, 504 F.3d 592 (5th Cir. 2007) (dismissal with prejudice when exhaustion is impossible)