Washington v. Malmud, et al., 2020 WL 6144707 (U.S.D.C. Oct. 20, 2020)

The plaintiff’s failure to name her employer in claims under Title VII and the ADEA is fatal to her claim.

The pro se plaintiff alleged that during her employment she was denied promotions and demoted due to her race, religion and age. The plaintiff filed a Charge of Discrimination with the EEOC and received a Right to Sue letter. She then filed a complaint against her employer; however, she later filed an amended complaint dropping her employer as a party and substituting individual co-workers, who had allegedly engaged in the discriminatory conduct. In dismissing the plaintiff’s amended complaint, Judge Hillman reiterated that neither Title VII or the ADEA allow for claims against individual parties and that the omission of the plaintiff’s employer from the amended complaint was fatal to the cause of action.


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