Williams v. Kipp Minn.

• Docket Number: Civil 23-2200 (JRT/ECW)
• Decision Date: 24 May 2024
• Parties: RODERICK WILLIAMS, Plaintiff, v. KIPP MINNESOTA, Defendant.
• Court: U.S. District Court — District of Minnesota

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RODERICK WILLIAMS, Plaintiff, v. KIPP MINNESOTA, Defendant.

Civil No. 23-2200 (JRT/ECW)

United States District Court, D. Minnesota

May 24, 2024

Eric D. Satre, SATRE LAW FIRM, International Plaza, 7900 International Drive, Suite 300-7044, Bloomington, MN 55425 for Plaintiff.

Dalia Istephanous and John P. Edison, RUPP, ANDERSON, SQUIRES &amp WALDSPURGER, 333 South Seventh Street, Suite 2800 Minneapolis, MN 55402, for Defendant.

MEMORANDUM OPINION AND ORDER GRANTING IN PART AND DENYING IN PART DEFENDANT'S MOTION FOR JUDGMENT ON THE PLEADINGS

JOHN R. TUNHEIM UNITED STATES DISTRICT JUDGE

PlaintiffRoderick Williams was terminated by KIPP Minnesota (“KIPP”) because of a report of violence against a student, but Williams claims that reason was merely pretextual and that KIPP terminated him because of his race.Williams brought three claims against KIPP, including race discrimination under 42 U.S.C. § 1981, defamation, and demand for payment under Minn. Stat. § 181.13.The § 181.13 claim has been resolved.KIPP now seeks dismissal of Williams's other claims.However, Williams has sufficiently alleged a claim of race discrimination under § 1981 and a claim of defamation under a theory of compelled self-publication.Accordingly, KIPP's motion for judgment on the pleadings will be granted in part as to the § 181.13 claim and denied in all other respects.

BACKGROUND

I.FACTS

Williams is an African American male who previously worked for KIPP as a paraprofessional.(Notice of Removal, Ex. C (“Am. Compl.”)¶¶ 1,3, July 24, 2023, DocketNo. 1.)KIPP is a nonprofit corporation operating charter public schools in Minnesota.(Id.¶ 2.)At KIPP, Williams worked with students who were disruptive and sometimes physically abusive.(Id.¶ 8.)

KIPP terminated Williams after a student claimed that Williams kicked him.(Id.¶¶ 9, 12, 32.)By Williams's account, when he returned from a brief restroom break the student stuck out his leg, resulting in Williams tripping and falling to the ground.(Id.¶¶ 9-11.)After the incident, the student left the room crying, and told another teacher that Williams had kicked him.(Id.¶ 16.)For the remainder of the day, Williams was assigned to a different classroom and other staff supervised the student.(Id.¶¶ 20, 24.)

Williams orally recounted his versions of the events to the principal but claims he was never provided an opportunity to review the statement.(Id.¶¶ 21-23.)Later that day, KIPP terminated Williams for “violence against a student.”(Id.¶ 27.)Williams alleges he was terminated without an opportunity to rebut any information or accusations made by the student.(Id.¶ 31.)He explains that everyone at KIPP is a mandated reporter, but nobody reported this incident to any authorities or law enforcement.(Id.¶¶ 28-29.)No adult witnesses observed the incident.(Id.¶ 14.)

Shortly after his termination, Williams received a Notice of Unsatisfactory Work Performance of Conduct (“Termination Notice”), which stated, “There have been warnings regarding performance and attendance.The latest act was violence against a student, therefore, warranting termination of our professional relationship and rights to the position.”(Id.¶¶ 37, 49.)Both in his complaint and at oral argument, Williams insists that he was later compelled to publish the Termination Notice but did not advise the Court to whom.(Id.¶ 53.)Williams acknowledges having a disciplinary history regarding his attendance and tardiness but alleges never having been “accused of or sanctioned for assaulting a student.”(Id.¶¶ 18, 33.)

Apart from the incident resulting in his termination, Williams pleads two other workplace grievances.Shortly before his termination, he had been trying to communicate with Human Resources regarding pay discrepancies.(Id.¶¶ 5-6, 36.)Williams also recounts discriminatory conduct he observed during his tenure, including a “clear racial double standard” with regard to teacher protection.(Id.¶ 34.)Specifically, Williams alleges that students who assaulted white teachers were disciplined, while those who assaulted Black teachers were not.(Id.)Williams also details an occasion when a white coworker was neither investigated nor terminated for “inappropriate physical interactions with students.”(Id.¶ 42.)

II.PROCEDURAL HISTORY

Williams initiated this action in Hennepin County District Court alleging race discrimination under the Minnesota Human Rights Act (“MHRA”); defamation; and a demand for payment owed under Minn. Stat. § 181.13.(See Notice of Removal, Ex.A.) KIPP filed a motion to dismiss.(Id., Ex. B.)Williams amended his complaint, substituting a claim for race discrimination under 42 U.S.C. § 1981 in lieu of his MHRA claim.(SeeAm. Compl. ¶¶ 41-48.)KIPP removed the action to federal court and filed a motion for judgment on the pleadings.(Notice of Removalat 1; Mot. for J. on the Pleadings, Sept. 19, 2023, DocketNo. 9.)

DISCUSSION

I.STANDARD OF REVIEW

Rule 12(c) of the Federal Rules of Civil Procedure provides that “[a]fter the pleadings are closed . . . a party may move for judgment on the pleadings.”Fed.R.Civ.P. 12(c).The Court analyzes a motion for judgment on the pleadings under the same standard as a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6).SeeAshley Cnty. v. Pfizer, Inc., 552 F.3d 659, 665(8^th Cir.2009).

In reviewing a motion to dismiss, the Court considers all facts alleged in the complaint as true to determine if the complaint states a “claim to relief that is plausible on its face.”Braden v. Wal-Mart Stores, Inc., 588 F.3d 585, 594(8^th Cir.2009)(quotingAshcroft v. Iqbal,556 U.S. 662, 678(2009)).The Court“accept[s] as true all facts pleaded by the non-moving party and grant[s] all reasonable inferences from the pleadings in favor of the non-moving party.”Syverson v. FirePond, Inc.,383 F.3d 745, 749(8^th Cir.2004)(quotingUnited States v. Any & All Radio Station Transmission Equip., 207 F.3d 458, 462(8^th Cir.2000)).However, the Court is “not bound to accept as true a legal conclusion couched as a factual allegation.”Papasan v. Allain,478 U.S. 265, 286(1986).In other words, a complaint “does not need detailed factual allegations” but must include more “than labels and conclusions, and a formulaic recitation of the elements” to meet the plausibility standard.Bell Atl. Corp. v. Twombly,550 U.S. 544, 555(2007).“Judgment on the pleadings is appropriate only when there is no dispute as to any material facts and the moving party is entitled to judgment as a matter of law.”Wishnatsky v. Rovner,433 F.3d 608, 610(8^th Cir.2006).

II.DEFENDANT'S MOTION FOR JUDGMENT ON THE PLEADINGS

KIPP moves for judgment on the pleadings arguing that Williams failed to adequately plead each claim.Williams informed the Court at oral argument that he would no longer pursue his Minn. Stat. § 181.13 claim, so the Court will grant KIPP's motion in part and dismiss that claim with prejudice.The Court rejects KIPPs' arguments as to the remaining claims and, accordingly, will deny the motion in part, allowing Williams's § 1981 and defamation claims to proceed.

A. 42 U.S.C. § 1981 Claim

Williams brings a claim for race discrimination under 42 U.S.C. § 1981.KIPP argues this claim is insufficient for two reasons.First, because Williams failed to plead two prima facie elements under the McDonnell Douglas framework.And second because he failed to plead that race was the “but for” cause of his termination.While both may be compelling reasons to grant summary judgment, neither are sufficient to grant KIPP's motion for judgment on the pleadings.

1.McDonnell Douglas Analysis

When alleging a claim of race discrimination under § 1981, a plaintiff may proceed on a disparate treatment or direct evidence theory.SeeWilson v. CFMOTO Powersports, Inc.,No. 15-3192, 2016 WL 912182, at *4(D. Minn.Mar. 7, 2016).To plead a case for disparate treatment under § 1981, courts apply the McDonnell Douglas burden shifting framework.Glover v. Am. Credit Acceptance,No. 22-1121, 2023 WL 158198, at *4(D. Minn.Jan. 11, 2023);Gordon v. Shafer Contracting Co., No. 04-3013, 2006 WL 738031, at *3(D. Minn.Mar. 22, 2006).The burden shifting framework first requires a plaintiff to prove a prima facie case of discrimination, after which the burden shifts to the employer to dispute that prima facie showing by articulating a non-discriminatory reason.Young v. Builders Steel Co.,754 F.3d 573, 577-78(8^th Cir.2014).If the employer provides a non-discriminatory reason, the burden shifts back to the plaintiff to show that the reason was pretextual for discrimination.Id. at 578.The prima facie requirements are not meant to be onerous.Putman v. Unity Health Sys., 348 F.3d 732, 735(8^th Cir.2003).

To plead a prima facie case of race discrimination using the McDonnell Douglas framework, a plaintiff must show: (1)he was a member of a protected class; (2)he was otherwise qualified or meeting his employer's legitimate expectations; (3)he suffered an adverse employment action; and (4) that the circumstances allow for an inference of discrimination.Burns v. Hy-Vee, Inc., No. 02-254, 2003 WL 21303185, *4(D. Minn.May 23, 2003)(citingTaylor v. Sw. Bell Telephone Co., 251 F.3d 735, 740(8^th Cir.2001));Young, 754 F.3d at 577.Discrimination can be inferred when similarly situated employees outside of the protected class are treated differently.Yang v. Robert Half Int'l, Inc.,79 F.4th 949, 964(8^th Cir.2023).

In this case, the only two elements in dispute are whether Williams was meeting KIPP's legitimate expectations and whether the circumstances allow for an inference of discrimination.

a. Meeting Employer's Legitimate Expectations

KIPP...