Searching over 5,500,000 cases.

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Eatman v. Jefferson County Department of Health

United States District Court, N.D. Alabama, Southern Division

October 15, 2014



KARON OWEN BOWDRE, District Judge.

This matter comes before the court on Defendant's "Motion to Dismiss or, in the Alternative, Motion for More Definite Statement." (Doc. 9). Plaintiff Kristal Eatman brings claims under Title VII of the Civil Rights Act of 1964, § 1983, and § 1981, alleging racial discrimination and retaliation arising out of Eatman's employment at Jefferson County Department of Health ("JCDH"). (Doc. 1). Defendant's motion, brought pursuant to Rules 12(b)(6) and 12(e), presents a variety of arguments for why this court should dismiss the complaint or, alternatively, enter an order directing Eatman to file a more definite statement.[1] (Doc. 9). For the following reasons, the court finds that the motion to dismiss is due to be granted as to some claims, and that the alternative motion for a more definite statement is due to be granted as to the remaining claims.


Plaintiff Kristal Eatman, a black female, was hired by Defendant Jefferson County Department of Health as a medical clerk on April 9, 2007. (Doc. 1). On January 28, 2012, Eatman was promoted to the position of Administrative Assistant III. Eatman alleges that following her promotion, she began to experience "racial hostility" from her supervisor, Dr. Teri Chafin, a white female. At the time of the alleged discriminatory actions, Dr. Chafin was the Director of Dental and Community Health for the Jefferson County Department of Health.

During February 2012, Eatman complained to the JCDH Director of Human Resources, Delores Johnson, about what she believed to be Dr. Chafin's disparate treatment of black and white employees. Johnson never responded to Eatman's complaint, and Eatman states that she began to suffer increased discriminatory treatment from Dr. Chafin after lodging her complaint. Specifically, Eatman states that Dr. Chafin refused to allow her to be trained for her position as an Administrative Assistant III, restricted her job duties, and threatened her with termination.

In July 2012, Eatman filed another complaint with JCDH, this time with Rodney Holmes, a JCDH official. Eatman alleges that following her filing of the second complaint, Dr. Chafin approached her and stated, "training you is going to be like training a monkey." Eatman further alleges that Dr. Chafin continued to retaliate against her by continuing to deny her training, belittling her in private and in public, and refusing to assign her work, which stunted her professional growth and adversely affected her suitability for other employment positions within JCDH. On November 16, 2012, Eatman was involuntarily assigned work at the Clinical Services Department of JCDH. As a result, Eatman is required to travel to two different JCDH job sites and has had to bear the financial costs of paying for her own fuel.

Eatman filed a claim with the EEOC on November 14, 2012, and received a right to sue letter on December 19, 2013.


A. Federal Rules of Civil Procedure 12(b)

A Rule 12(b)(6) motion to dismiss attacks the legal sufficiency of the complaint. Generally, the Federal Rules of Civil Procedure require only that the complaint provide "a short and plain statement of the claim' that will give the defendant fair notice of what the plaintiff's claim is and the grounds upon which it rests." Conley v. Gibson, 355 U.S. 41, 47 (1957) (quoting Fed.R.Civ.P. 8(a)). A plaintiff must provide the grounds of her entitlement, but Rule 8 generally does not require "detailed factual allegations." Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (quoting Conley, 355 U.S. at 47). It does, however, "demand[] more than an unadorned, the-defendant-unlawfully-harmed-me accusation." Ashcroft v. Iqbal 556 U.S. 662, 678 (2009). Pleadings that contain nothing more than "a formulaic recitation of the elements of a cause of action" do not meet Rule 8 standards nor do pleadings suffice that are based merely upon "labels or conclusions" or "naked assertions" without supporting factual allegations. Twombly, 550 U.S. at 555, 557.

The Supreme Court explained that "[t]o survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.'" Iqbal, 556 U.S. at 678 (quoting and explaining its decision in Twombly, 550 U.S. at 570). To be plausible on its face, the claim must contain enough facts that "allow[] the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." Iqbal, 556 U.S. at 678. Although "[t]he plausibility standard is not akin to a probability requirement, '" the complaint must demonstrate "more than a sheer possibility that a defendant has acted unlawfully." Id. "Where a complaint pleads facts that are merely consistent with a defendant's liability, it stops short of the line between possibility and plausibility of entitlement to relief.'" Id. (quoting Twombly, 550 U.S. at 557).

The Supreme Court has recently identified "two working principles" for the district court to use in applying the facial plausibility standard. The first principle is that, in evaluating motions to dismiss, the court must assume the veracity of well-pleaded factual allegations; however, the court does not have to accept as true legal conclusions even when "couched as [] factual allegation[s]" or "threadbare recitals of the elements of a cause of action, supported by mere conclusory statements." Iqbal, 556 U.S. at 678. The second principle is that "only a complaint that states a plausible claim for relief survives a motion to dismiss." Id. at 679. Thus, under prong one, the court determines the factual allegations that are well-pleaded and assumes their veracity, and then proceeds, under prong two, to determine the claim's plausibility given the well-pleaded facts. That task is "context-specific" and, to survive the motion, the allegations must permit the court based on its "judicial experience and common sense... to infer more than the mere possibility of misconduct." Id. If the court determines that well-pleaded facts, accepted as true, do not state a claim that is plausible, the claim must be dismissed. Id.

B. "Shotgun" Pleadings and Rules 8(a)(2) and 8(d)(1)

JCDH asserts in its motion to dismiss that Plaintiff's complaint is a "shotgun pleading" that is too vague to allow for the Defendant to prepare a response. The Eleventh Circuit has frequently condemned shotgun pleadings for violating the Federal Rules of Civil Procedure. See, e.g., Chapman v. Al Transp., 229 F.3d 1012, 1027 (11th Cir. 2000) ( en banc ). Rule 8(a)(2) requires a pleading to contain a "short and plain statement of the claim" that shows that the pleader is entitled to relief. Fed.R.Civ.P. 8(a)(2). The purpose of this requirement is to "give the defendants fair notice of what the... claim is and the grounds upon which it rests." Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007). Rule 8(d) also demands that "[e]ach allegation [in a pleading] must be simple, concise, and direct." Fed.R.Civ.P. 8(d)(1). Shotgun pleadings, however, are neither "short and plain, " nor "simple, concise, and direct." A shotgun pleading requires a defendant, as well as a court, to "sift through the facts presented and decide for [itself] which were material to the particular cause of action asserted." Pelletier v. Zweifel, 921 F.2d 1465, 1518 ...

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.