HILL v. KLM RESTAURANT CORPORATION
2:24-cv-01121
E.D. Pa.
Jun 6, 2024
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Opinion Summary

Facts

  1. Ivan Lee Matthews, a California prisoner, is suing the current and former Wardens of Salinas Valley State Prison under 42 U.S.C. § 1983 for alleged Eighth Amendment violations related to his time in administrative segregation. [lines="15-17"]
  2. Plaintiff alleges that while on "suicide watch" for 22 days, he experienced extreme sleep deprivation, high blood pressure, and pain due to the conditions of his confinement. [lines="46-58"]
  3. Matthews filed complaints about these conditions with Warden Foss, raising concerns about the failure to train correctional officers. [lines="61-66"]
  4. M. Atchley became warden after Matthews filed his complaints, but Matthews did not receive a response to his request for intervention regarding the conditions. [lines="75-80"]
  5. The trial court ultimately found that Matthews' complaint did not provide enough factual allegations to support claims against the defendants based on supervisory liability. [lines="255-256"]

Issues

  1. Whether the complaint sufficiently alleges Eighth Amendment violations based on supervisory liability by defendants Foss and Atchley. [lines="202-203"]
  2. Whether the defendants are entitled to qualified immunity regarding the alleged Eighth Amendment violations. [lines="492-493"]

Holdings

  1. The court held that Matthews failed to allege sufficient facts to support a claim for supervisory liability, as the defendants were not directly involved in the alleged constitutional violations. [lines="189-190"]
  2. The court ruled that the defendants were entitled to qualified immunity because it was not clearly established in 2019 that the conduct of conducting suicide watch checks, which created noise, violated the Eighth Amendment. [lines="446-447"]

OPINION

IMANI HILL v. KLM RESTAURANT CORPORATION d/b/a CHICK-FIL-A

No. 24-CV-01121

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

JUNE 5, 2024

KENNEY, J.

MEMORANDUM

The Court writes for the benefit of the parties and will assume the parties’ familiarity with the facts and nature of this case.1

Defendant moved to dismiss (ECF No. 10) Count III - allegations of sex discrimination, disability discrimination, and retaliation in violation of the Pennsylvania Human Relations Act (“PHRA“) - in Plaintiff‘s original Complaint (ECF No. 1), on the grounds that Plaintiff has failed to exhaust her administrative remedies under the PHRA. Plaintiff did not file a response. Instead, Plaintiff filed an Amended Complaint (ECF No. 11) as of right. However, Plaintiffs Amended Complaint fails to address or remedy Count III‘s defects, as raised by Defendant in their Motion to Dismiss. Thus, because the Court finds merit to Defendant‘s position that Plaintiff has failed to exhaust her administrative remedies under the PHRA, the Court will dismiss Count III of the Amended Complaint, for the reasons discussed below.

A motion to dismiss is appropriate if there is a “failure to state a claim upon which relief can be granted.” Fed. R. Civ. P. 12(b)(6). To survive a Rule 12(b)(6) motion to dismiss, “a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.‘” (quoting ). A plaintiff must “plead[] factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” (citing ). The factual allegations must “raise a right to relief above the speculative level.” .

Here, because Defendant‘s claim that Plaintiff has failed to exhaust her administrative remedies under the PHRA is “‘in the nature of statutes of limitation’ and ‘does not affect the district court‘s subject matter jurisdiction,’ this issue is best resolved under Rule 12(b)(6).” (quoting ).

In employment discrimination cases involving the PHRA, claims must first be brought to the Pennsylvania Human Relations Commission (“PHRC“). The PHRC then has one year of exclusive jurisdiction to investigate the claim. ; see also 43 Pa.C.S. § 962(c)(1). A complainant cannot file suit until they have exhausted their administrative remedies with the PHRC during that one-year period. (citing ).

Here, Plaintiff, a female employee at Defendant‘s restaurant, dual-filed claims of discrimination and retaliation with the Equal Employment Opportunity Commission (“EEOC“) and the PHRC on October 30, 2023. ECF No. 1 ¶ 15. The EEOC issued its Notice of Right to Sue on December 22, 2023, which gives a complainant 90 days to file suit in either federal or state court. ECF No. 1 ¶ 16. Plaintiff filed her complaint on March 14, 2024, ECF No. 1. Defendant then moved to dismiss Plaintiff‘s claims in Count III on the grounds that Plaintiff had failed to exhaust her administrative remedies with the PHRA. ECF No. 10. Plaintiff did not respond to Defendant‘s Motion to Dismiss, and instead filed an Amended Complaint on June 4, 2024. ECF No. 11. The PHRC still has not issued a response, however, and the PHRC‘s exclusive jurisdiction of one year to resolve the claim has still not expired.

This case parallels , where the plaintiff dual-filed claims with the EEOC and PHRC, received a Notice of Right to Sue from the EEOC only, yet filed both claims in federal court before the PHRA‘s one year of exclusive jurisdiction had lapsed. . There, the court granted Defendant‘s motion to dismiss the PHRA claim without prejudice, allowing Plaintiff to file an amended complaint following exhaustion of the appropriate administrative remedies. . Here, despite receiving the Notice of Right to Sue from the EEOC, Plaintiff‘s PHRA claim in both her original Complaint, as well as her newly filed Amended Complaint, is premature because the PHRC has neither dismissed nor investigated the matter within one year. 43 Pa.C.S. § 962(c)(1). Thus, Defendant‘s Count III is dismissed.

BY THE COURT:

/s/ Chad F. Kenney

CHAD F. KENNEY, J.

Notes

1
See .
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