John Farmer de la Torre sued Catholic Charities of Southern Missouri, Inc. (CCSM), the Diocese of Springfield-Cape Girardeau, and eight individual defendants in the United States District Court for the Western District of Missouri, alleging violations of Title VII based on sex and national origin discrimination. The Diocese, individual defendants, and CCSM filed motions to dismiss under Rule 12(b)(6).
Factual Overview
Farmer de la Torre served as CCSM’s Director of Communications and Marketing from December 2018 until his termination on March 1, 2023. He filed a complaint with the EEOC on December 21, 2023, alleging discrimination from November 30, 2022 to March 1, 2023. According to his allegations, after complaining to human resources about discrimination based on being a Hispanic male, he was placed on a Performance Improvement Plan that he claimed was retaliatory. Despite receiving positive feedback in February 2023, he was terminated on March 1, 2023. After receiving his right to sue letter on January 17, 2024, he filed this lawsuit on April 18, 2024, alleging discrimination from November 10, 2020 to March 1, 2024.
Legal Analysis
Diocese’s Motion to Dismiss: The court first addressed whether Farmer de la Torre properly exhausted his administrative remedies against the Diocese. The court found that he failed to include the Diocese in his EEOC complaint and did not sufficiently allege how the Diocese had a sufficient identity of interest with CCSM. The court dismissed these claims without prejudice, allowing him to amend his complaint.
Individual Defendants’ Liability: The court found that individual supervisors cannot be held liable under Title VII in the Eighth Circuit. Since none of the individual defendants qualified as employers under the statute, the court dismissed all claims against them with prejudice.
Timeliness of Claims: The court determined that claims arising before February 24, 2023 (300 days before the EEOC filing) were time-barred. Additionally, any claims after March 1, 2023, were beyond the scope of the EEOC charge. However, the retaliatory discharge claim from March 1, 2023, could proceed as it fell within both the limitations period and the scope of the EEOC charge.
The court granted the individual defendants’ motion to dismiss with prejudice, sustained the Diocese’s motion without prejudice, and partially granted CCSM’s motion to dismiss claims outside the relevant time period.
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