Plaintiff Diana Suzuki-Tyrey sued The Rehabilitation Institution of St. Louis (TRISL), BJC Health, and Encompass Health Corporation in the Eastern District of Missouri, alleging employment discrimination and retaliation under Title VII, the Americans with Disabilities Act (ADA), the Rehabilitation Act, and the Family and Medical Leave Act (FMLA). The defendants moved to dismiss the plaintiff’s claims under Federal Rule of Civil Procedure 12(b)(6).
Factual Overview
The plaintiff alleged she experienced employment discrimination based on race, color, disability, and FMLA status. She claimed she had diabetes and underwent surgery related to that condition. The plaintiff alleged she was retaliated against when coworkers excluded her from meetings and when she had to work while fellow employees watched movies. She further claimed her employer failed to promote her and eventually terminated her employment due to insufficient patients in the hospital. On April 8, 2022, she filed a Charge of Discrimination with the EEOC, alleging disability discrimination and retaliation against TRISL.
Legal Analysis
Claims Against BJC and Encompass: The court dismissed all claims against BJC and Encompass because the plaintiff failed to allege any employment relationship with these defendants. Additionally, she failed to exhaust administrative remedies by not including these defendants in her EEOC charge.
Title VII Claims Against TRISL: The court found the plaintiff failed to exhaust administrative remedies for her race and color discrimination claims because she did not check these boxes on her EEOC charge or mention such discrimination in her narrative.
ADA Claims Against TRISL: The court determined the plaintiff failed to state a claim under the ADA because she did not sufficiently allege that her diabetes substantially limited any major life activity or that her termination was due to her disability. The court noted she explicitly stated she was terminated due to insufficient patients.
Rehabilitation Act Claim: The court dismissed this claim because the plaintiff failed to allege she was a qualified individual with a disability and did not explain how the Rehabilitation Act applied to TRISL, particularly regarding federal funding.
FMLA Claim: The court found the FMLA claim was time-barred because the alleged discrimination occurred between 2018 and 2020, and the plaintiff did not file her claim within the two-year statute of limitations.
The court granted the defendants’ motions to dismiss all claims.
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