Plaintiff Lynette R. Jackson sued American Water Utility (properly known as American Water Works Service Company, Inc.) in the United States District Court for the Eastern District of Missouri, raising claims of employment discrimination, FMLA violations and retaliation, employee benefit violations, harassment, whistleblowing, wage violations, and violation of the CARES Act. Defendant moved to dismiss the claims under Rule 12(b)(6) or alternatively sought a more definite statement under Rule 12(e).
Factual Overview
Jackson, proceeding pro se, filed a one-page petition in state court listing various claims against American Water but provided no factual allegations whatsoever to support these claims. After American Water removed the case to federal court based on federal question and diversity jurisdiction, it filed a motion arguing that Jackson’s claims were barred by claim preclusion and the doctrine of claim splitting, and alternatively sought a more definite statement. Jackson did not timely respond to the motion to dismiss, leading the court to issue a show cause order. She later filed a response and supplement, with the latter being stricken for lack of signature.
Legal Analysis
Motion to Dismiss and Motion for More Definite Statement:
The court found that while Jackson’s petition completely lacked factual allegations, this same deficiency made it impossible to evaluate whether her claims were precluded by prior litigation or constituted improper claim splitting. Rather than dismiss the case, the court determined that requiring Jackson to provide a more definite statement would better serve the interests of justice.
Requirements for Amended Complaint: The court outlined specific requirements for Jackson’s amended complaint, including that it must comply with Rules 8 and 10 of the Federal Rules of Civil Procedure, set forth claims in a simple and direct manner, and provide a timeframe for each allegation. The court emphasized that the amended complaint would completely replace the original complaint and must be signed.
The court granted defendant’s motion for a more definite statement, denied without prejudice the motion to dismiss, ordered the clerk to provide Jackson with an employment discrimination complaint form, and set a deadline of January 21, 2025, for Jackson to file an amended complaint.
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