Tunstall v. William E. Donaldson Correctional Facility, 2:24-cv-01504

Plaintiff J. Corbin Tunstall, an African-American male, was employed by the Alabama Department of Corrections (ADOC) at the William E. Donaldson Correctional Facility as a sergeant.
On October 13, 2021, an inmate under Tunstall’s supervision died from a stab wound after an altercation; Tunstall was put on mandatory leave and not paid.
Tunstall resigned February 7, 2022, and was terminated two days later by Commissioner Hamm, allegedly for not obtaining medical treatment for the inmate.
Tunstall alleges a similarly situated white sergeant was not placed on leave or terminated initially for the same incident.
Tunstall filed an EEOC charge one day after his termination and asserts claims of race discrimination and retaliation under Title VII, § 1981, and § 1983 against ADOC, Donaldson Facility, and Commissioner Hamm.
Defendants moved to dismiss, arguing pleading deficiencies, improper parties, Eleventh Amendment immunity, and qualified immunity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Shotgun Pleading	Complaint provides sufficient notice of claims.	Complaint is a shotgun pleading, overly vague and incorporates all allegations.	Complaint is a shotgun pleading and must be amended.
Proper Parties for Title VII	All defendants liable under Title VII.	Only the actual employer (ADOC) is proper; Donaldson and Hamm are not proper parties.	Claims against Donaldson and Hamm under Title VII dismissed; only ADOC remains.
Eleventh Amendment Immunity	Claims properly asserted for damages.	ADOC, Donaldson, and Hamm (official capacity) are shielded by state immunity under § 1981 and § 1983.	§ 1981 and § 1983 claims for damages dismissed against state entities and Hamm in official capacity.
Qualified Immunity	Hamm not entitled to qualified immunity.	Hamm is entitled to qualified immunity for actions in individual capacity.	Court cannot yet rule due to deficient pleading—awaits amended complaint.

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (sets plausibility standard for pleadings)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (articulates required specificity for pleadings)
Maynard v. Bd. of Regents, 342 F.3d 1281 (11th Cir. 2003) (defines employer liability under Title VII)
Will v. Mich. Dep’t of State Police, 491 U.S. 58 (1989) (state agencies/entities entitled to Eleventh Amendment immunity)
Busby v. City of Orlando, 931 F.2d 764 (11th Cir. 1991) (no individual liability under Title VII)