Enoch v. Inman
Case Details
- Judge(s)
- Geer, McGee, Bryant
- Status
- Published
- Procedural Posture
- Appeal of motion to dismiss; appellate reversal
Related Laws
No specific laws identified for this ruling.
Claim Types
Outcome
Trial court's motion to dismiss of plaintiff's race discrimination claims was reversed. Appellate court held that failure to explicitly cite § 1983 does not require dismissal and that allegations were sufficient to support equal protection claims under § 1983 and Title VII.
Excerpt
<bold>Public Officers and Employees — race discrimination claim — §</bold> <bold>1983 — Title VII</bold> <block_quote> The trial court erred by granting defendants' motion to dismiss plaintiff county DSS employee's race discrimination claims even though the complaint appears to attempt to assert a claim directly under the federal constitution instead of referencing <cross_reference>42 U.S.C. § 1983</cross_reference>, because: (1) the mere fact that a complaint neglects to specify that it is based on § 1983 does not require dismissal even though referencing the statute is the more preferable course; (2) the allegations in the complaint were sufficient to support a § 1983 claim for violation of plaintiff's equal protection rights against both defendant DSS director individually and defendant DSS employer; and (3) a state or local government employee may pursue claims of race discrimination under Title VII, § 1983, or both.</block_quote>
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