Williams v. Aramark Campus LLC
1:23-cv-01082
E.D. Cal.Sep 29, 2023Background:
- Plaintiff worked as a cashier for Aramark at a store located inside Yosemite National Park (a federal enclave) from 2017 until his termination in Feb. 2023 after a workplace hip injury and medical leave.
- Plaintiff filed a 16‑count complaint in California state court (June 7, 2023) asserting numerous state employment torts/statutory claims and one federal claim under the FMLA; the case was removed to federal court.
- Defendants moved to dismiss, principally arguing the federal enclave doctrine bars most California statutory and tort claims because Yosemite became a federal enclave in 1920.
- Plaintiff conceded many state‑law claims are barred but sought leave to amend the FMLA retaliation claim (4th) and negligent hiring/supervision/retention claim (13th); he argued pleading deficiencies stemmed from state‑court pleading practices.
- The magistrate judge recommended dismissing with prejudice all state claims that post‑date the 1920 cession (including FEHA, CFRA, UCL, etc.), dismissing Wright (individual) with prejudice, and granting leave to amend only the 4th (FMLA retaliation) and 13th (negligent hiring) claims subject to specified limits.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Applicability of federal enclave doctrine to state claims | Most state common‑law negligence claims predate 1920 and survive; statutory claims are barred but negligence claims may persist | Yosemite became an exclusive federal enclave in 1920; state statutes and tort doctrines first recognized after 1920 do not apply | Court: Federal enclave doctrine bars state statutes and any state causes of action recognized after 1920; many claims conceded or dismissed with prejudice |
| Negligent infliction of emotional distress (NIED) | NIED is grounded in California general negligence (Civ. Code §1714) and thus survives enclave doctrine | NIED was first recognized as a distinct tort in Molien (1980), long after the 1920 cession, so it is barred | Court: NIED is barred by the federal enclave doctrine and dismissed with prejudice |
| Negligent hiring, supervision, & retention | This is a general employer negligence claim traceable to pre‑1920 common law (Rahmel) and thus not enclave‑barred; requests leave to amend to cure pleading defects | Even if not enclave‑barred, complaint fails to plead facts identifying unfit employees or how Aramark knew of unfitness; portions based on FEHA are barred | Court: Claim is not categorically barred by the enclave doctrine but complaint inadequately pleaded; dismiss with leave to amend narrowly to assert non‑FEHA negligent hiring/supervision/retention with factual detail |
| FMLA retaliation claim (4th) | Plaintiff alleges retaliation related to medical leave; requests leave to amend because pleading was drafted under state standards | Complaint contains inconsistent facts, does not allege Plaintiff took FMLA leave or that he opposed an FMLA‑protected practice; leave to amend would be futile if leave exceeded 12 weeks | Court: FMLA retaliation claim is inadequately pleaded (failure to allege opposing unlawful FMLA practices or taking protected leave); dismissed with leave to amend to plead a proper theory if possible |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (complaint must state factual content that permits plausible claim for relief)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
- Parker Drilling Mgmt. Servs., Ltd. v. Newton, 139 S. Ct. 1881 (2019) (state laws enacted after federal cession presumptively do not apply in federal enclaves)
- Paul v. United States, 371 U.S. 245 (1963) (state law existing at time of acquisition continues unless it conflicts with federal policy)
- Molien v. Kaiser Found. Hospitals, 27 Cal. 3d 916 (1980) (recognition of negligent infliction of emotional distress as distinct tort)
- Rahmel v. Lehndorff, 142 Cal. 681 (1904) (early recognition that employer may be liable for negligently hiring/retaining servants with known violent propensities)
- Xin Liu v. Amway Corp., 347 F.3d 1125 (9th Cir. 2003) (distinguishing FMLA interference and retaliation theories)
- Bachelder v. Am. W. Airlines, Inc., 259 F.3d 1112 (9th Cir. 2001) (describing FMLA rights to leave and reinstatement)
- Lopez v. Smith, 203 F.3d 1122 (9th Cir. 2000) (leave to amend should be freely given to permit decisions on merits)
- Foman v. Davis, 371 U.S. 178 (1962) (standards for denying leave to amend)