Johnson v. Regional Supplemental Services Inc

U.S. District Court, District of Minnesota

Johnson v. Regional Supplemental Services Inc

Trial Court Opinion

                 UNITED STATES DISTRICT COURT                           
                    DISTRICT OF MINNESOTA                               

William Douglas Johnson, III,          Case No. 24-CV-323 (PJS/JFD)     



              Plaintiff,                                                

v.                                                                      

ORDER

Regional Supplemental Services, Inc.; and                               
Management Specialty Services 109, Inc.,                                

              Defendants.                                               


   Magistrate Judge John F. Docherty previously ordered plaintiff William Douglas 
Johnson, III, to show cause why the District of Minnesota is the proper venue for this 
action.  ECF No. 3.  As Judge Docherty explained, under 
28 U.S.C. § 1391
(b), 
        [a] civil action may be brought in —                            
             (1) a judicial district in which any defendant             
             resides, if all defendants are residents of the            
             State in which the district is located;                    

             (2) a judicial district in which a substantial part        
             of the events or omissions giving rise to the              
             claim occurred, or a substantial part of                   
             property that is the subject of the action is              
             situated; or                                               

             (3) if there is no district in which an action may         
             otherwise be brought as provided in this                   
             section, any judicial district in which any                
             defendant is subject to the court’s personal               
             jurisdiction with respect to such action.                  
This District appears to fit none of those conditions.  The defendants are residents of 
New York, and the events giving rise to the claim (Johnson’s purported “refusal to 
test”) took place in Alabama.  ECF No. 1.                                 

   In response to the order to show cause, Johnson does not dispute that none of the 
defendants are residents of this District or that the events giving rise to his claims 
occurred in Alabama.  ECF No. 4.  Indeed, Johnson seemingly concedes that proper 

venue in this District is lacking, asking for this Court to transfer the matter to the proper 
federal district court.1  
Id.
                                             
   Section 1406(a) grants district courts the discretion to either “dismiss, or if it be in 
the interest of justice, [to] transfer” matters filed in an improper district.  But, for two 

reasons, this Court concludes that transfer is not in the interests of justice.  First, it is not 
clear on the face of the complaint whether it would be most appropriate to transfer this 
action to New York or Alabama.  Second, and more importantly, it is not clear that 

Johnson has pleaded a plausible claim for relief.                         


1 Johnson also says that he lives in St. Paul and “handled the appeal against the FMCSA 
in this district to get the violation removed case number 23-2900.” (ECF No. 4).  This 
Court understands “FMCSA” to mean Federal Motor Carrier Safety Administration.  
But there is no case number “23-2900” in this District naming Johnson as the plaintiff 
and the FMCSA as a defendant.  Although records show that Johnson filed a complaint 
against the United States Department of Transportation (US DOT) and the Civil Rights 
Division of the US DOT, that action was dismissed without prejudice for failure to state 
a claim.  See Johnson v. Dept. of Transp., Case No. 23-CV-02559 (PJS/DJF) (D. Minn. 
Aug. 21, 2023).                                                           
   In reviewing whether a complaint states a claim on which relief may be granted, 
a court must accept as true all of the factual allegations in the complaint and draw all 

reasonable inferences in the plaintiff's favor.  See Aten v. Scottsdale Ins. Co., 
511 F.3d 818, 820
 (8th Cir. 2008).  Although the factual allegations in the complaint need not be 
detailed, they must be sufficient to “raise a right to relief above the speculative 

level . . . .”  Bell Atl. Corp. v. Twombly, 
550 U.S. 544, 555
 (2007).  The complaint must 
“state a claim to relief that is plausible on its face.”  
Id. at 570
.  In assessing the 
sufficiency of the complaint, the court may disregard legal conclusions that are couched 

as factual allegations.  See Ashcroft v. Iqbal, 
556 U.S. 662
 (2009).  Pro se complaints are to 
be construed liberally, but they still must allege sufficient facts to support the claims 
advanced.  See Stone v. Harry, 
364 F.3d 912, 914
 (8th Cir. 2004).         
   Here, Johnson alleges that when he reported to Brookwood Baptist Health 

Specialist Care in Birmingham, Alabama to submit a urine sample, the urine collector 
directed him to sign a “Federal Drug Testing Custody and Control Form.”  ECF No. 1.  
Johnson says that he refused to sign that form and that he was subsequently reported as 

having “refus[ed] to test.”  As the Court understands it, Johnson’s claim goes something 
like this:  Requiring Johnson to sign the “Federal Drug Testing Custody and Control 
Form” violated 
49 C.F.R. § 40.355
(a), a regulation promulgated by the Federal Motor 
Carrier Safety Administration (“FMCSA”), which regulation prohibits drug-testing 

companies from requiring employees to sign “a consent, release, waiver of liability, or 
indemnification agreement with respect to any part of the drug or alcohol testing 
process.”                                                                 

   But Johnson does not identify any language in the “Federal Drug Testing 
Custody and Control Form” that he was asked to sign that constitutes a prohibited 
release, waiver of liability, or indemnification agreement.  In response to Judge 

Docherty’s order to show cause, Johnson submitted the form, but he does not plead any 
specific facts explaining how signing that form constitutes (for example) a waiver of the 
drug-testing company’s liability.  See ECF No. 5.  Indeed, FMCSA regulations expressly 

contemplate the use of this exact form—the Federal Drug Testing Custody and Control 
Form (“CCF”)—“to document the handling of the urine specimen from the time the 
employee gives the specimen to the collector until the specimen is destroyed.” 
49 C.F.R. § 40.3
; see, e.g., 
49 C.F.R. § 40.40
(a) (explaining that the “[CCF] must be used to 

document every collection required by the DOT drug testing program”).  Accordingly, 
in the absence of any specific allegations establishing how signing the “Federal Drug 
Testing Custody and Control Form” constitutes a violation of 
49 C.F.R. § 40.355
(a)--

particularly where, as here, federal regulations require the drug-testing companies to 
document the urine sample’s chain of custody--this Court doubts that Johnson has 
established a plausible cause of action.                                  
    This Court, therefore, declines to grant Johnson’s request to transfer this action. 
Instead, the Court dismisses this matter without prejudice.  If he wishes, Johnson may 
refile his complaint in the proper district in New York or Alabama. 

ORDER

    Based on the foregoing, and on all of the files, records, and proceedings herein, 
IT IS HEREBY ORDERED THAT: 
          1.     Plaintiff William Douglas Johnson, III’s Complaint, [ECF No. 1], is 
                DISMISSED WITHOUT PREJUDICE. 
          2.     Plaintiffs IFP Application, [ECF No. 2], is DENIED as MOOT. 
          LET JUDGMENT BE ENTERED ACCORDINGLY. 
                                       heel  het 
Dated: March 25, 2024                      A        —       
                                      Phitrick J. Schiltz, Chiéf Judge 
                                       United States District Judge

Trial Court Opinion

                 UNITED STATES DISTRICT COURT                           
                    DISTRICT OF MINNESOTA                               

William Douglas Johnson, III,          Case No. 24-CV-323 (PJS/JFD)     



              Plaintiff,                                                

v.                                                                      

ORDER

Regional Supplemental Services, Inc.; and                               
Management Specialty Services 109, Inc.,                                

              Defendants.                                               


   Magistrate Judge John F. Docherty previously ordered plaintiff William Douglas 
Johnson, III, to show cause why the District of Minnesota is the proper venue for this 
action.  ECF No. 3.  As Judge Docherty explained, under 
28 U.S.C. § 1391
(b), 
        [a] civil action may be brought in —                            
             (1) a judicial district in which any defendant             
             resides, if all defendants are residents of the            
             State in which the district is located;                    

             (2) a judicial district in which a substantial part        
             of the events or omissions giving rise to the              
             claim occurred, or a substantial part of                   
             property that is the subject of the action is              
             situated; or                                               

             (3) if there is no district in which an action may         
             otherwise be brought as provided in this                   
             section, any judicial district in which any                
             defendant is subject to the court’s personal               
             jurisdiction with respect to such action.                  
This District appears to fit none of those conditions.  The defendants are residents of 
New York, and the events giving rise to the claim (Johnson’s purported “refusal to 
test”) took place in Alabama.  ECF No. 1.                                 

   In response to the order to show cause, Johnson does not dispute that none of the 
defendants are residents of this District or that the events giving rise to his claims 
occurred in Alabama.  ECF No. 4.  Indeed, Johnson seemingly concedes that proper 

venue in this District is lacking, asking for this Court to transfer the matter to the proper 
federal district court.1  
Id.
                                             
   Section 1406(a) grants district courts the discretion to either “dismiss, or if it be in 
the interest of justice, [to] transfer” matters filed in an improper district.  But, for two 

reasons, this Court concludes that transfer is not in the interests of justice.  First, it is not 
clear on the face of the complaint whether it would be most appropriate to transfer this 
action to New York or Alabama.  Second, and more importantly, it is not clear that 

Johnson has pleaded a plausible claim for relief.                         


1 Johnson also says that he lives in St. Paul and “handled the appeal against the FMCSA 
in this district to get the violation removed case number 23-2900.” (ECF No. 4).  This 
Court understands “FMCSA” to mean Federal Motor Carrier Safety Administration.  
But there is no case number “23-2900” in this District naming Johnson as the plaintiff 
and the FMCSA as a defendant.  Although records show that Johnson filed a complaint 
against the United States Department of Transportation (US DOT) and the Civil Rights 
Division of the US DOT, that action was dismissed without prejudice for failure to state 
a claim.  See Johnson v. Dept. of Transp., Case No. 23-CV-02559 (PJS/DJF) (D. Minn. 
Aug. 21, 2023).                                                           
   In reviewing whether a complaint states a claim on which relief may be granted, 
a court must accept as true all of the factual allegations in the complaint and draw all 

reasonable inferences in the plaintiff's favor.  See Aten v. Scottsdale Ins. Co., 
511 F.3d 818, 820
 (8th Cir. 2008).  Although the factual allegations in the complaint need not be 
detailed, they must be sufficient to “raise a right to relief above the speculative 

level . . . .”  Bell Atl. Corp. v. Twombly, 
550 U.S. 544, 555
 (2007).  The complaint must 
“state a claim to relief that is plausible on its face.”  
Id. at 570
.  In assessing the 
sufficiency of the complaint, the court may disregard legal conclusions that are couched 

as factual allegations.  See Ashcroft v. Iqbal, 
556 U.S. 662
 (2009).  Pro se complaints are to 
be construed liberally, but they still must allege sufficient facts to support the claims 
advanced.  See Stone v. Harry, 
364 F.3d 912, 914
 (8th Cir. 2004).         
   Here, Johnson alleges that when he reported to Brookwood Baptist Health 

Specialist Care in Birmingham, Alabama to submit a urine sample, the urine collector 
directed him to sign a “Federal Drug Testing Custody and Control Form.”  ECF No. 1.  
Johnson says that he refused to sign that form and that he was subsequently reported as 

having “refus[ed] to test.”  As the Court understands it, Johnson’s claim goes something 
like this:  Requiring Johnson to sign the “Federal Drug Testing Custody and Control 
Form” violated 
49 C.F.R. § 40.355
(a), a regulation promulgated by the Federal Motor 
Carrier Safety Administration (“FMCSA”), which regulation prohibits drug-testing 

companies from requiring employees to sign “a consent, release, waiver of liability, or 
indemnification agreement with respect to any part of the drug or alcohol testing 
process.”                                                                 

   But Johnson does not identify any language in the “Federal Drug Testing 
Custody and Control Form” that he was asked to sign that constitutes a prohibited 
release, waiver of liability, or indemnification agreement.  In response to Judge 

Docherty’s order to show cause, Johnson submitted the form, but he does not plead any 
specific facts explaining how signing that form constitutes (for example) a waiver of the 
drug-testing company’s liability.  See ECF No. 5.  Indeed, FMCSA regulations expressly 

contemplate the use of this exact form—the Federal Drug Testing Custody and Control 
Form (“CCF”)—“to document the handling of the urine specimen from the time the 
employee gives the specimen to the collector until the specimen is destroyed.” 
49 C.F.R. § 40.3
; see, e.g., 
49 C.F.R. § 40.40
(a) (explaining that the “[CCF] must be used to 

document every collection required by the DOT drug testing program”).  Accordingly, 
in the absence of any specific allegations establishing how signing the “Federal Drug 
Testing Custody and Control Form” constitutes a violation of 
49 C.F.R. § 40.355
(a)--

particularly where, as here, federal regulations require the drug-testing companies to 
document the urine sample’s chain of custody--this Court doubts that Johnson has 
established a plausible cause of action.                                  
    This Court, therefore, declines to grant Johnson’s request to transfer this action. 
Instead, the Court dismisses this matter without prejudice.  If he wishes, Johnson may 
refile his complaint in the proper district in New York or Alabama. 

ORDER

    Based on the foregoing, and on all of the files, records, and proceedings herein, 
IT IS HEREBY ORDERED THAT: 
          1.     Plaintiff William Douglas Johnson, III’s Complaint, [ECF No. 1], is 
                DISMISSED WITHOUT PREJUDICE. 
          2.     Plaintiffs IFP Application, [ECF No. 2], is DENIED as MOOT. 
          LET JUDGMENT BE ENTERED ACCORDINGLY. 
                                       heel  het 
Dated: March 25, 2024                      A        —       
                                      Phitrick J. Schiltz, Chiéf Judge 
                                       United States District Judge

Reference

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