Plaintiff Regina M. Hill sued defendant MHM Support Services in the United States District Court for the Eastern District of Missouri raising claims under Title VII of the Civil Rights Act of 1964 and the Americans with Disabilities Act (ADA), including claims of discrimination based on race, color, national origin, disability, and retaliation. Defendant MHM Support Services moved to dismiss all claims.
Factual Overview
Hill was hired as a patient care assistant at MHM Support Services in December 2022. She alleged she informed her employer of her disability (fibromyalgia) and need for accommodation. During training, Hill claimed she witnessed discrimination against people of color and reported it. After complaining, Hill alleged she was demoted, placed on unpaid leave, and ultimately terminated in May 2023. Hill initially filed discrimination charges with the EEOC and received a right-to-sue letter. She filed her original complaint pro se in July 2024, which was partially dismissed. She then filed an amended complaint that is the subject of this opinion.
Legal Analysis
ADA Claims: The court dismissed Hill’s ADA claims because she failed to allege how her fibromyalgia substantially impaired a major life activity or how it affected her work. The court also found Hill failed to allege she faced adverse employment action because of her disability.
Title VII Discrimination Claims: The court dismissed Hill’s race, color, and national origin discrimination claims because she failed to exhaust administrative remedies by not including these claims in her EEOC charge. Additionally, Hill failed to allege she was meeting her employer’s legitimate expectations or that she was treated differently than similarly situated employees.
Title VII Retaliation Claim: The court preserved Hill’s retaliation claim, finding she sufficiently alleged she engaged in protected activity by complaining about discrimination and subsequently suffered adverse employment actions.
Procedural Requirements: The court ordered Hill to file a second amended complaint with numbered paragraphs as required by Federal Rule of Civil Procedure 10(b), finding her current complaint made it difficult for the defendant to respond.
The court granted in part and denied in part the motion to dismiss, preserving only Hill’s Title VII retaliation claim while dismissing all other claims without prejudice, and ordered Hill to file a properly formatted second amended complaint within 30 days.
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