In Reed v. St. Louis Pub. Schools Board of Education, the plaintiff, Leslie Rachel Reed, a self-represented individual, filed a complaint alleging discrimination in violation of Title VII of the Civil Rights Act of 1964 and the Americans with Disabilities Act of 1990 against her former employer the St. Louis Public School Board of Education.
Plaintiff’s Factual Allegations
Reed claimed that starting August 16, 2022, she faced harassment, including “assaulting statements,” “false defamation statements,” and “physical assaulting with sexual touches” at work. She said that she was discriminated against due to her race and disability, seeking $10,000 in lost wages. Reed’s EEOC Charge, filed on June 30, 2023, exclusively mentioned disability discrimination. She described being orally abused and constructively discharged due to harassment related to her disability, diagnosed in 1996. She also claimed to be constructively discharged.
Summary of Arguments and Court’s Rulings
Failure to Exhaust Administrative Remedies (Title VII Claims): The court noted that to bring a Title VII claim, a plaintiff must first exhaust administrative remedies with the EEOC. In Reed’s case, the court found that her Title VII claims, including race and sex discrimination, were not exhausted as they were not mentioned in her EEOC charge. The court dismissed these claims for failure to exhaust administrative remedies.
Disability Discrimination Claim: The court considered the disability discrimination claim under the Americans with Disabilities Act. It observed that Reed’s complaint did not comply with the Federal Rules of Civil Procedure, as it lacked clarity and specifics about her disability and how it was related to the alleged discrimination. That said, the court decided not to dismiss this claim but granted the defendant’s motion for a more definite statement, allowing Reed to amend her complaint.
Conclusion: In conclusion, the court ordered that the defendant’s motion to dismiss the Title VII claims was granted, leading to the dismissal of the racial discrimination, sex discrimination, and sexual harassment claims. The motion to dismiss the disability discrimination claim was denied, but a more definite statement was granted. Reed was instructed to file an amended complaint for the disability discrimination claim within 28 days, failing which the court would dismiss the action without further notice
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