Michael Anthony Christopher Cochren II sued White Castle System, Inc. and the Equal Employment Opportunity Commission (EEOC) in the Eastern District of Missouri, alleging racial discrimination and retaliation under Title VII of the Civil Rights Act of 1964, as well as constitutional claims against the EEOC. Both defendants moved to dismiss – White Castle under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim, and the EEOC under both Rule 12(b)(1) for lack of subject matter jurisdiction and Rule 12(b)(6).
Factual Overview
Cochren filed his complaint on August 19, 2024, alleging that he was subjected to racial discrimination and ultimately terminated by White Castle in retaliation due to complaints he made to White Castle Team Members Services/HR/Corporate Management. Prior to his termination, Cochren reported issues including harassment, labor theft, application contradictions, unsafe work environment, nepotism, and unsafe food to human resources. White Castle terminated him based on insubordination, hostility, hostile language with the HR department, and violating company policy.
Regarding the EEOC, Cochren alleged an “unsatisfactory Charge of Discrimination and EEOC process” and claimed the EEOC engaged in “knowingly changing and purposefully neglecting details about the Charge and Amended Charge of Discrimination.” He sought $80,000,000 in damages and cited Title VII and the United States Constitution as the basis for jurisdiction over his claims against both defendants.
Legal Analysis
Claims Against White Castle
Retaliation Claim: The court analyzed whether Cochren adequately pled (1) protected conduct and (2) a causal link between the protected conduct and adverse employment action. The court found Cochren failed to allege facts demonstrating his workplace issues were related to discrimination based on race, color, religion, sex, or national origin as prohibited by Title VII. Additionally, even if Cochren had adequately pled protected conduct, the court found he failed to show more than a mere temporal connection between his complaints and termination.
Race Discrimination Claim: The court examined whether Cochren (1) met White Castle’s legitimate expectations and (2) alleged circumstances permitting an inference of discrimination. The court found Cochren’s own pleadings indicated he did not meet employer expectations, as he admitted to being terminated for insubordination and hostile behavior. The court also found Cochren’s single conclusory allegation of racial discrimination insufficient to permit an inference of discrimination.
Claims Against EEOC
Subject Matter Jurisdiction: The court found it lacked jurisdiction over both Title VII and constitutional claims against the EEOC. Title VII does not contain a waiver of sovereign immunity for suits against the EEOC except where the federal government is the employer, which was not the case here. Similarly, constitutional claims do not waive the EEOC’s sovereign immunity.
Failure to State a Claim: The court found that even if it had jurisdiction, Cochren failed to state viable claims. Congress has not authorized any cause of action against the EEOC for its handling of discrimination charges, and courts have consistently held that the EEOC’s investigative, non-adjudicatory procedures do not implicate constitutional rights.
The court granted both defendants’ motions to dismiss and dismissed all claims with prejudice.
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