Nelson Brown sued Meridian Medical Technologies, Inc. in the United States District Court for the Eastern District of Missouri, raising claims of race, color, and age discrimination under the Missouri Human Rights Act (MHRA), Title VII of the Civil Rights Act, and the Age Discrimination in Employment Act (ADEA). Defendant Meridian Medical Technologies, Inc. moved to partially dismiss Plaintiff’s First Amended Complaint under Rule 12(b)(6).
Factual Overview
Nelson Brown, a 62-year-old African American male, has been employed by Meridian Medical Technologies as a Production Mechanic at their Brentwood campus since June 1979. Brown alleges that despite being the senior-most employee, he did not receive adequate training on the Auto-Injector Filling Machine (AIFM), which prevented him from qualifying for a pay raise under the company’s Incentive Program. He claims that younger, Caucasian employees with less tenure were given opportunities to complete the training and earn extra compensation.
Brown complained about this alleged discriminatory treatment to his supervisors, HR department, and through a union grievance. He claims that after each complaint, he experienced additional discriminatory behavior, particularly from Mr. Thomas, who allegedly assigned Brown menial tasks and unnecessarily scrutinized his work. Brown filed a charge of discrimination with the EEOC on March 3, 2021, which was dually filed with the Missouri Commission on Human Rights. The EEOC issued a Right to Sue letter on September 26, 2022, and Brown filed this action on December 22, 2022.
Legal Analysis
Timeliness of Title VII and ADEA Claims: The court addressed the timeliness of Brown’s Title VII and ADEA claims. It noted that to exhaust administrative remedies, a plaintiff must timely file a charge with the EEOC within 180 days of the alleged unlawful employment practice, or within 300 days if the charge is also filed with a state or local agency. The court found that Brown’s claims based on events occurring before May 25, 2020 (300 days before his EEOC charge) were time-barred.
Continuing Violation Doctrine: The court considered whether Brown’s claims could be saved by the continuing violation doctrine. It explained that this doctrine allows a plaintiff to recover for all illegal acts that made up a hostile work environment if at least one act falls within the statutory period. However, the court found that Brown’s allegations described discrete acts of discrimination rather than a continuing hostile environment, and therefore, the doctrine did not apply.
Missouri Human Rights Act Claims: Regarding Brown’s MHRA claims, the court noted that Missouri law requires filing a verified complaint with the Missouri Human Rights Commission within 180 days of the alleged discrimination. Additionally, a plaintiff must sue within 90 days of receiving a right-to-sue letter, but not more than two years after the complained-of conduct. The court found that Brown filed his MHRA claims before receiving his right-to-sue letter, which was not issued until January 19, 2023. As a result, the court determined that Brown’s MHRA claims were unexhausted and must be dismissed.
The court granted Defendant’s Motion to Dismiss, dismissing Brown’s Title VII and ADEA claims to the extent they were based on discrete acts of discrimination occurring more than 300 days before his EEOC charge was filed, and dismissing his MHRA claims as time-barred.
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