Watson v. Williamsburg Collegiate Charter, 1:17-cv-04150

Background

Plaintiff Kimberly Watson, proceeding pro se, sued Williamsburg Collegiate Charter School under Title VII alleging race- and religion-based employment discrimination after workplace treatment changed following a staff religious-preference survey.
Watson alleges exclusion by Principal Alexandra Bronson and Director of Operations Natalya Shulga, relocation to an undesirable office, a negative 2016 performance evaluation after three prior positive evaluations, and a June 2016 termination notice.
She received an EEOC Dismissal and Notice of Rights on April 20, 2017, then filed this federal complaint on July 11, 2017; she paid the filing fee after in forma pauperis was denied.
The complaint named the employer and two individual supervisors as defendants and invoked Title VII for race and religion claims.
The Court found the pleadings deficient for failing to allege nonconclusory facts plausibly connecting adverse actions to a protected characteristic, and noted temporal proximity alone is insufficient to show discriminatory intent.
The Court directed Watson to file an amended complaint within 30 days alleging additional facts supporting a plausible Title VII religious-discrimination claim and to remove individual defendants (Title VII does not permit individual liability).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Watson pleaded plausible Title VII discrimination	Watson asserts adverse actions (exclusion, relocation, bad eval, termination) followed her indicating religion-based discrimination after she marked "other" on a survey	Defendant (implicitly) challenges that facts do not tie adverse actions to protected status; workplace complaints may be non-discriminatory	Complaint fails to plead nonconclusory facts plausibly showing discrimination; allowed leave to amend to add facts supporting a religion-based claim
Whether individual supervisors can be sued under Title VII	Watson named Bronson and Shulga as defendants	N/A; law bars individual liability under Title VII	Individual employees not proper defendants; amended complaint must name only the employer
Pleading standard applicable to pro se Title VII claims	Watson relies on her pro se allegations and minimal factual detail	Court applies Twombly/Iqbal plausibility standard, but construes pro se pleadings liberally	Pro se status affords leniency, but claims must still include nonconclusory factual matter to be plausible; plaintiff given opportunity to amend
Whether temporal proximity alone suffices to infer discrimination	Watson points to timing between survey and adverse actions	Law requires more than temporal proximity to infer discriminatory intent	Temporal proximity alone insufficient to establish discriminatory intent; plaintiff must allege additional facts showing pretext or discriminatory motive

Key Cases Cited

Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (establishes plausibility pleading standard)
Ashcroft v. Iqbal, 556 U.S. 662 (applies plausibility standard to discrimination and other claims)
Erickson v. Pardus, 551 U.S. 89 (pro se complaints construed liberally)
Sealed Plaintiff v. Sealed Defendant #1, 537 F.3d 185 (2d Cir. 2008) (pro se pleading lenity in Second Circuit)
Littlejohn v. City of New York, 795 F.3d 297 (2d Cir. 2015) (minimal facts may support inference of discriminatory motivation at pleading stage)
Vega v. Hempstead Union Free Sch. Dist., 801 F.3d 72 (2d Cir. 2015) (plaintiff must allege adverse action at least in part for discriminatory reason)
EEOC v. Port Auth. of N.Y. & N.J., 768 F.3d 247 (2d Cir. 2014) (complaint must nudge claims from conceivable to plausible)
Brown v. Henderson, 257 F.3d 246 (2d Cir. 2001) (mistreatment action under Title VII actionable only when because of protected characteristic)
El Sayed v. Hilton Hotels Corp., 627 F.3d 931 (2d Cir. 2010) (temporal proximity alone insufficient to prove discriminatory intent)
Wrighten v. Glowski, 232 F.3d 119 (2d Cir. 2000) (Title VII does not permit suits against individual employees)
Tomka v. Seiler Corp., 66 F.3d 1295 (2d Cir. 1995) (individual liability not available under Title VII)
Coppedge v. United States, 369 U.S. 438 (addressing good-faith standard for in forma pauperis appeals)