August 25th, 2017
US Court of Appeals for the Fifth Circuit Opinions
Body by Cook, Inc. v. State Farm Mutual Automobile Insurance
Opinion Date: August 24, 2017
Judge: Stephen Andrew Higginson
Areas of Law: Civil Rights, Constitutional Law
Plaintiffs filed suit against national insurance companies, alleging various civil rights violations under 42 U.S.C. 1981, 1985, and Title VII, as well as several related state law claims. The Fifth Circuit held that the district court did not err in dismissing plaintiffs' claims notwithstanding the district court's ruling that the complaint satisfied Federal Rule of Civil Procedure 8. In this case, a complaint, such as the one at issue, may simultaneously satisfy Rule 8's technical requirements but fail to state a claim under Rule 12(b)(6). The court also held that the district court erred in dismissing Body by Cook's section 1981 contract claim against State Farm, but the district court properly dismissed Robert Cook's section 1981 claim against State Farm and plaintiffs' section 1981 claim against all other defendants. Furthermore, the district court did not err in dismissing plaintiffs' section 1985(3) conspiracy claims; plaintiff failed to allege that defendants retaliated against them; and Cook failed to allege facts sufficient to demonstrate the existence of a prospective employment relationship as to this Title VII discrimination and retaliation claims. Finally, the district court did not abuse its discretion by refusing plaintiffs another opportunity to plead their case and dismissing plaintiffs' federal claims with prejudice. Accordingly, the court affirmed in part, reversed in part, and remanded.
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