Baldwin v. Metropolitan Water Reclamation
Baldwin v. Metropolitan Water Reclamation
Opinion of the Court
ORDER
Barbara Baldwin challenges the dismissal of her complaint alleging that the Metropolitan Water Reclamation District of Greater Chicago discriminated against her on the basis of race, sex, and age when it refused to hire her as a paralegal. Because Baldwin pleaded herself out of court by acknowledging that she does not have the training needed to work for the Reclamation District as a paralegal, we affirm the judgment.
Baldwin was certified as a paralegal in 1996 by the Professional Career Development Institute. That school’s program is not accredited by the American Bar Association, and the Reclamation District will not hire any paralegal applicant who doesn’t have a certificate from an ABA-approved program. In 2010, when she was 56 years old, Baldwin applied for a vacant position, but the Reclamation District told her that she was ineligible because her certification does not satisfy its hiring criteria. Baldwin, who is black, concedes all of these facts, but after being rejected, she filed a charge of discrimina
Baldwin then sued in the district court. The body of her complaint mentions no constitutional or statutory provision, and for that reason the Reclamation District argued that the suit should be dismissed for lack of subject-matter jurisdiction. The defendant also contended that Baldwin’s complaint fails to state a claim. The district court implicitly rejected the jurisdictional contention but agreed with the Reclamation District that Baldwin’s suit must be dismissed because her allegations show that a missing credential is why she could not be hired.
Baldwin appeals, but she does not dispute the district court’s reading of her complaint.
We have considered Baldwin’s remaining contentions, and all are without merit.
AFFIRMED.
. Apparently the Reclamation District stands by its contention that the district court lacked subject-matter jurisdiction because Baldwin’s complaint does not link her claim of discrimination to a specific federal statute or constitutional provision. That understanding is incorrect. A complaint is satisfactory if it states a claim for which relief in the federal court is available; the plaintiff can supply the legal theory later. E.g., Rabé v. United Air Lines, 636 F.3d 866, 872 (7th Cir. 2011); Williams v. Seniff, 342 F.3d 774, 792 (7th Cir. 2003); Bartholet v. Reishauer A.G. (Zürich), 953 F.2d 1073, 1078 (7th Cir. 1992). In any event, the Reclamation District is wrong in saying that Baldwin’s complaint does not mention a federal statute. She attached, and thus incorporated into her complaint, the right-to-sue letter, see Fed.R.Civ.P. 10(c); Geinosky v. City of Chicago, 675 F.3d 743, 745 n. 1 (7th Cir. 2012), and this document makes obvious that Baldwin’s complaint arises under Title VII and the ADEA. Though a right-to-sue letter standing alone would not qualify as a complaint, Baldwin Cnty. Welcome Ctr. v. Brown, 466 U.S. 147, 150, 104 S.Ct. 1723, 80 L.Ed.2d 196 (1984), we will not judge a plaintiff’s complaint "so narrowly as to foreclose the full adjudication of her claim on the mere failure to cite Title VII explicitly,” Brown v. Reliable Sheet Metal Works, Inc., 852 F.2d 932, 933 n. 1 (7th Cir. 1988); see also Judkins v. Beech Aircraft Corp., 745 F.2d 1330, 1332 (11th Cir. 1984) (relying on right-tosue letter along with underlying charge of discrimination detailing factual basis for plaintiff's discrimination claim).
Reference
- Full Case Name
- Barbara BALDWIN v. METROPOLITAN WATER RECLAMATION DISTRICT OF GREATER CHICAGO
- Cited By
- 2 cases
- Status
- Published