Princess Martha (the retirement community where Brayan applied for employment) in its charge of discrimination and did not name the TJM entities (the management companies). The court denied the motion. The court found that the EEOC provided sufficient notice to the defendant, and that the entities were given ample time to participate in the conciliation process prior the EEOC filing the lawsuit. The court thereby denied the motion for failure to exhaust administrative remedies. The defendants also contended that the EEOC failed to provide sufficient evidence for a single/integrated enterprise or joint employer relationship. The TJM entities claimed that the complaint lacked details on centralized control, common management, common ownership, and financial control. The EEOC asserted that the complaint adequately outlined a plausible basis for holding TJM liable under both theories. The court concluded that the EEOC’s complaint contained specific factual allegations that plausibly established that the TJM entities and the Princess Martha were highly integrated with respect to their ownership and operation. Id . at *23. The court stated that the TJM Properties and the Princess Martha shared a human resources director, who reviewed and revised employee handbooks and policies and conduct trainings on the policies for the Princess Martha and TJM's other regional facilities, Princess Martha employees received benefits through TJM Properties, and TJM Property Management’s agreement with the Princess Martha required it to review and assist the Princess Martha with employment and payroll policies, and manage its budget, information systems, supplies, and insurance. Id . at *23-24. TJM Property Management also issued job postings for the Princess Martha and operated some of its hiring procedures. Id . at *24. The court held that the EEOC’s allegations were more than sufficient to plausibly allege that both TJM entities' operations were interrelated with the Princess Martha. Additionally, the court ruled that at this stage of the litigation, the complaint only needed to establish a sufficient factual foundation to plausibly allege the joint employer liability claim. The court rejected the defendants’ argument that the EEOC’s allegations were conclusory, and concluded that the complaint was sufficiently detailed to survive a motion to dismiss. Accordingly, the court denied the defendants’ motion to dismiss on all grounds. In EEOC v. Telecare Mental Health Services of Washington, Inc. , the EEOC brought claims for ADA discrimination on behalf of a charging party who alleged he was denied employment due to his leg impairment. The following three decisions discuss impactful rulings in quick succession across this case. First, in EEOC v. Telecare Mental Health Services Of Washington, Inc., 2023 U.S. Dist. LEXIS 101869 (W.D. Wash. June 12, 2023), the EEOC filed an action on behalf of charging party Jason Hautala, alleging that the defendant violated the Americans with Disabilities Act (ADA) by denying Hautala employment due to his leg impairment. The defendant argued that EEOC failed to demonstrate material issues of fact on several elements of its claims such that summary judgment was appropriate. The court granted the motion, finding that the EEOC failed to meet its burden of demonstrating a prima facie case of disability discrimination under the ADA. Hautala applied for a registered nurse position at the defendant ’ s mental health facility, which provides care to adult residents with serious mental health disorders. Job duties for nurses include performing physical tasks such as administering medications, CPR, and restraining violent clients
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© Duane Morris LLP 2024
The EEOC Litigation Review – 2024
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