Plaintiff Dora Pelletier sued defendants Saint Louis University and SSM Health Care Group in the United States District Court for the Eastern District of Missouri raising claims of discrimination under Title VII and the Missouri Human Rights Act based on sex discrimination and retaliation. Defendants moved to dismiss plaintiff’s Missouri Human Rights Act claims under Rule 12(b)(6), and plaintiff moved to stay the motions to dismiss pending resolution of her state court mandamus action.
Factual Overview
Plaintiff was employed by Saint Louis University and SSM Health Care Group from September 2022 until her termination in June 2023. After filing discrimination charges with the Missouri Commission on Human Rights and the Equal Employment Opportunity Commission in August 2023, the MCHR issued notices in December 2023 finding that defendants were not covered by the Missouri Human Rights Act because they are owned and operated by religious organizations. Plaintiff then filed a mandamus action in Missouri state court seeking to compel the MCHR to issue a right-to-sue letter, arguing either that defendants should be covered by the MHRA or that the religious exemption is unconstitutional. Rather than responding to defendants’ motions to dismiss her federal MHRA claims, plaintiff moved to stay the federal proceedings until the state mandamus case is resolved.
Legal Analysis
Motion to Stay
The court analyzed plaintiff’s request to stay the federal proceedings pending resolution of her state court mandamus action. Plaintiff argued that the cases were parallel and that the state action would be resolved quickly since summary judgment briefing was complete. The court rejected these arguments, finding that the cases were not truly parallel because they involved separate issues – the state case concerned whether defendants were exempt from the MHRA and whether the statute was constitutional, while the federal case involved both Title VII and MHRA discrimination claims. The court also noted that even completed briefing did not guarantee imminent resolution, as appeals could extend the state proceedings significantly. Applying the traditional stay factors, the court found that granting an indefinite stay would prejudice both parties by risking loss of evidence and witness memories, and that the interests of justice favored proceeding with the federal case since the Title VII claims could move forward regardless of the state court outcome.
Motion to Dismiss MHRA Claims
The court addressed defendants’ challenge to plaintiff’s Missouri Human Rights Act claims based on her failure to obtain a right-to-sue letter from the MCHR. Under established Eighth Circuit precedent, Missouri law requires plaintiffs to exhaust their administrative remedies before bringing MHRA claims, including obtaining a right-to-sue letter from the MCHR. The court noted that this requirement is a condition precedent, though not a jurisdictional prerequisite, to filing an MHRA action. Since plaintiff conceded that she had not received a right-to-sue letter and could not maintain her MHRA claims under current Missouri law, the court granted defendants’ motion to dismiss the state law discrimination claims.
The court denied plaintiff’s motion to stay and granted defendants’ motions to dismiss counts I and III (the Missouri Human Rights Act claims) without prejudice, while allowing the federal Title VII claims to proceed.
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