Wills v. MPF Federal, LLC
1:23-cv-01158
D. MarylandApr 14, 2025Background
- Plaintiff Katelyn Kelly Wills worked as a veterinary technician and then Project Manager under a contract at a U.S. Army facility, moving across several private contractors, most recently MPF Federal, LLC.
- After disclosing her pregnancy, Wills was terminated by MPF for alleged lack of required certifications.
- Wills filed sex and pregnancy discrimination claims under Title VII (federal) and the Maryland Fair Employment Practices Act (state), naming both MPF and the Army as joint employers.
- The Army moved to dismiss claiming failure to exhaust administrative remedies, lack of joint employer status, and lack of waiver of sovereign immunity under MFEPA.
- The case was previously stayed but the stay was lifted after the dismissal ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sovereign Immunity under MFEPA | Army is liable under MFEPA as joint employer | No waiver of sovereign immunity for state claims | Dismissed MFEPA claim against Army with prejudice |
| Title VII Administrative Exhaustion | Filing with EEOC/MCCR met exhaustion requirement | Failed to initiate Army's own process (45-day rule) | Dismissed Title VII claim against Army without prejudice |
| Army as Joint Employer under Title VII | Army controlled her employment through contract requests | Army did not supervise, hire/fire, or control terms | Army not plausibly a joint employer |
| Sufficiency of Discrimination Allegations | Army was aware of pregnancy and responsible for termination | No facts showing Army's discriminatory animus | No sufficient facts to support Title VII claim |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (sets plausibility pleading standard for Rule 12(b)(6) motions)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (requires plausible factual allegations, not mere labels or conclusions)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (establishes burden-shifting framework for Title VII claims)
- Fort Bend County v. Davis, 587 U.S. 541 (2019) (charge-filing with EEOC is not jurisdictional but still required)
- Butler v. Drive Automotive Industries of America, Inc., 793 F.3d 404 (4th Cir. 2015) (sets test for joint employer status under Title VII)