859 F. Supp. 2d 824
E.D. La.2012Background
- Williams was hired by Recovery School District (RSD) in August 2006 as a math teacher, with his last assignment at Clark High School.
- On October 2, 2009, Williams requested extended sick leave for spinal stenosis and allegedly provided extensive medical records.
- During the leave request process, Williams, a 63-year-old African American man, contends that white representatives told him to retire.
- RSD approved extended leave from October 5 to November 2, 2009, but Williams received a November 17, 2009 letter stating he was discharged for excessive use of sick leave and job abandonment.
- Williams alleges discrimination on the basis of race, age, and disability and also claims retaliatory acts after an EEOC charge; he filed suit on July 6, 2011 after receiving an EEOC Right‑to‑Sue letter; an amended complaint added LDOE and BESE; RSD moved to dismiss in October 2011.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether RSD is a suable entity under Louisiana law | Williams contends RSD can be sued as a separate unit. | RSD is not a juridical person capable of suing or being sued. | RSD is not a juridical person; claims against RSD are dismissed. |
| Race discrimination under Title VII | Williams alleges race-based adverse treatment. | No showing others similarly situated were treated more favorably; allegations are conclusory. | Title VII race-discrimination claim dismissed. |
| Retaliation under Title VII | Williams alleges retaliation after protected activity. | Acts alleged are not materially adverse or causally linked to protected activity. | Title VII retaliation claim dismissed. |
| ADA and ADEA claims against LDOE and BESE | LDOE and BESE are proper defendants for ADA/ADEA claims. | Eleventh Amendment sovereign immunity bars these claims; states did not waive immunity. | ADA and ADEA claims against LDOE and BESE dismissed with prejudice. |
| Injunctive relief claims | Requests broad injunctive relief to end discrimination and institute policies. | No viable statutory claims; relief would be overbroad and vague. | Injunctive relief claim dismissed with prejudice. |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (plausibility pleading standard)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (facial plausibility required; not mere conjecture)
- Raggs v. Miss. Power & Light Co., 278 F.3d 463 (5th Cir. 2002) (causal link for retaliation must be more than mere temporal proximity)
- Burlington Northern & Santa Fe Ry. Co. v. White, 548 U.S. 53 (U.S. 2006) (retaliation standard requires material adversity)
- Clark County Sch. Dist. v. Breeden, 532 U.S. 268 (U.S. 2001) (temporal proximity must be very close for causal inference in retaliation)