Plaintiff Casey Litz sued defendant New Prime, Inc. in the United States District Court for the Western District of Missouri, alleging claims of sex discrimination, sexual harassment/hostile work environment, negligence, negligent infliction of emotional distress, and breach of contract. Before the court was plaintiff’s motion for leave to file a third amended complaint to reassert claims under the Missouri Human Rights Act (MHRA) that she had previously abandoned.
Factual Overview
Plaintiff alleged that while employed as a driver for New Prime, she suffered sexual abuse, sexual discrimination, and severe emotional distress by her driving trainer Edwin Reyes on November 3, 2021. She filed a charge of discrimination with the EEOC and MCHR on May 2, 2022. The EEOC issued a right-to-sue letter on June 1, 2023. Plaintiff filed her initial complaint on August 30, 2023, asserting MHRA claims and common law claims, but without having obtained an MCHR right-to-sue letter. After New Prime moved to dismiss based on failure to exhaust administrative remedies, plaintiff filed an amended complaint replacing her MHRA claims with Title VII claims. The MCHR issued plaintiff a right-to-sue letter on August 26, 2024, and plaintiff moved to amend her complaint to reassert the MHRA claims.
Legal Analysis
Relation Back of Previously Abandoned Claims: The court rejected New Prime’s argument that plaintiff could not reassert previously abandoned claims. The court found that because the MHRA claims were based on the same operative facts as the original complaint and New Prime had notice of these claims from the outset, the relation back doctrine applied.
Timeliness of Prematurely Filed Claims: The court distinguished between untimely claims filed after the statute of limitations expires and prematurely filed claims filed before exhausting administrative remedies. The court found that premature filing could be cured by subsequent receipt of a right-to-sue letter.
Undue Delay: While acknowledging plaintiff’s delay in requesting the MCHR right-to-sue letter, the court found that delay alone was insufficient grounds to deny amendment absent a showing of prejudice to the defendant. New Prime did not demonstrate any prejudice would result from allowing the amendment.
The court granted plaintiff’s motion for leave to file a third amended complaint, allowing her to reassert her MHRA claims.
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