Plaintiff Dana Watson sued defendant Crossroads Hospice of St. Louis, LLC in the United States District Court for the Eastern District of Missouri raising claims of employment discrimination under the Rehabilitation Act of 1973, Section 1981 of the Civil Rights Act of 1866, Title VII of the Civil Rights Act of 1964, and the Americans with Disabilities Act of 1990. Defendant moved to dismiss plaintiff’s Title VII and ADA claims under Rule 12(b)(6).
Factual Overview
Watson worked for Crossroads Hospice for several months in 2022 before she was terminated. She filed a complaint against the company, originally naming it as “Crossroads Hospice and Palliative Care.” The defendant filed a motion to correct its name to Crossroads Hospice of St. Louis, LLC.
Watson filed discrimination claims under multiple federal statutes. In her complaint, she indicated that she had not received a right-to-sue letter from the Equal Employment Opportunity Commission (EEOC). In response to the motion to dismiss, Watson argued that she had exhausted all remedies because the EEOC had her case for almost two years without contacting her for information or updates. She also stated that the EEOC failed to contact her with a resolution after several calls and emails.
Legal Analysis
Exhaustion of Administrative Remedies: The court explained that Title VII and ADA plaintiffs are required to exhaust their administrative remedies with the EEOC or a comparable state agency before bringing a formal action. This exhaustion requirement serves to provide the EEOC the first opportunity to investigate discriminatory practices and enables it to perform its roles of obtaining voluntary compliance and promoting conciliatory efforts.
Requirements for Exhaustion: The court outlined two requirements for exhausting administrative remedies: (1) timely filing a charge of discrimination with the EEOC setting forth the facts and nature of the charge, and (2) receiving notice of the right to sue.
Plaintiff’s Failure to Exhaust: The court noted that Watson did not claim to have received a right-to-sue letter for her Title VII and ADA claims. In her complaint, she indicated that she had not received such a letter. The court acknowledged Watson’s frustration with the EEOC’s delay in processing her charge of discrimination but stated that she could not bring her Title VII and ADA claims until the EEOC provided her notice of a right to sue.
The court granted the defendant’s motion to dismiss Watson’s Title VII and ADA claims and granted the motion to correct the defendant’s name.
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