Mills v. Kansas, Eighth Judicial District
Docket: No. Civ.A. 97-4097-DES
Court: District Court, D. Kansas; February 24, 1998; Federal District Court
Defendants filed a Motion to Dismiss under Rules 12(b)(6) and 12(b)(1) of the Federal Rules of Civil Procedure regarding a case brought by five current and former court services officers for the Eighth Judicial District, Riley County District Court. Plaintiffs allege that the State violated affirmative action and equal employment opportunity protocols by improperly promoting or reclassifying two individuals. They claim to have faced retaliation starting in July 1994, which intensified following their complaint to the Kansas Human Rights Commission and the Equal Employment Opportunity Commission in March 1995. Specific retaliatory actions cited include creating a hostile work environment, hindering promotion and training opportunities, encouraging other employees to isolate them, excluding them from management meetings, and unfair disciplinary measures. In evaluating the Rule 12(b)(6) motion, the court must accept all well-pleaded factual allegations as true and draw reasonable inferences in favor of the plaintiffs while determining if they can prove any set of facts that could support their claims. For the Rule 12(b)(1) motion, the court emphasizes that it has limited jurisdiction and can only act when jurisdiction is explicitly granted. If jurisdiction is questioned, the plaintiff must demonstrate that the court has the authority to hear the case, or it may be dismissed at any stage of the proceedings. Title VII of the Civil Rights Act prohibits employment discrimination based on race, color, religion, sex, or national origin, as well as retaliation against individuals opposing such discrimination or filing charges under Title VII. To establish a prima facie case for retaliation, plaintiffs must demonstrate: 1) engagement in protected opposition to discrimination; 2) an adverse action taken by the employer following this protected activity; and 3) a causal link between the adverse action and the protected activity. In this case, the plaintiffs did not assert claims of discrimination based on the aforementioned protected categories, leading the court to determine that their complaints do not constitute statutorily prohibited discrimination. As a result, the court found that the plaintiffs failed to present a valid claim under Title VII, granting the defendants' Motion to Dismiss.