govinfo:USCOURTS-mdd-1_25-cv-02724-0

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND LATOYA HUNT, Plaintiff, v. CAROLYN SCRUGGS, et al., Defendants. * * * * * Civil Action No. GLR-25-2724 *** MEMORANDUM OPINION THIS MATTER is before the Court on Defendants Danielle Callahan, Carolyn Scruggs, and Kerri Smith22). The Motion is ripe for disposition, and no hearing is necessary. See Local Rule 105.6 (D.Md. 2025). For the reasons set forth below, the Court will grant the Motion to Dismiss in part and deny it in part. I. BACKGROUND A. Factual Background1 In August 2023, Plaintiff Latoya Hunt began working as a parole and probation agent I with the Maryland Department of Public Safety and Correctional Services ) Division of Parole and Probation at their Elkton office. (Compl. ¶ 14, ECF No. 1). Hunt identifies as an African American woman. (Id. ¶ 13). 1 Unless otherwise noted, the Court takes the following facts from the Complaint (ECF No. 1) and accepts them as true. See Erickson v. Pardus, 551 U.S. 89, 94 (2007). 

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Defendant Kerry Smith, a white Caucasian woman who serves as Field Supervisor I, was assigned to supervise Hunt. (Id. ¶ 19). Hunt alleges that, at the outset, Smith was a bad supervisor and treated her differently from her similarly situated colleagues. (See id. ¶¶ 26, 37 n.5). For example, as a new employee, Hunt was required to attend a training program located in Sykesville, Maryland, but Smith did not help Hunt with assignments that Hunt needed to complete to graduate from the training program. (Id. ¶¶ 2428). When Hunt ultimately graduated from the training program and was ready to take on her own cases, Smith staffed Hunt with a sixty-case caseload. (Id. ¶¶ 3537). Hunt alleges that one of the other white Caucasian agents similarly situated such as Ms. Erin Tracy and Mr. Jordan Ramsburg had to start out with sixty (60) cases transferred to themId. ¶ 37 n.5). For example, around December 2023, when Hunt the folder open, told Hunt that she was missing documents, and then proceeded Id. ¶¶ 4046). Hunt felt so uncomfortable by this interaction that she emailed Smith and copied the management team, including Field Supervisor II, Defendant Danielle Callahan, a white Caucasian woman, to let them know it occurred. (Id. ¶ 47). Callahan acknowledged receiving the email but did nothing further. (Id. ¶ meditator in a meeting between Hunt and Smith. (Id. ¶ 50). In that meeting, Hunt mentioned how uncomfortable Smith made her. (Id. ¶ 52espite [Smith] indicating that she got along with all the other African American employees . . . numerous complaints have been 

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made regarding treatment of African American employees.Id. ¶¶ 5455). Hunt explains several instances in which other African American agents were treated differently than their white counterparts, including, for example, Defendants Smith and Callahan bullying other African American agents or not giving them opportunities for promotion. (Id. ¶¶ 5564). According to Hunt, the hostility only continued. For instance, around January 2024, in her office when Smith threw her hands in the air and screamed, I am just trying to help you. (Id. ¶ 69). Smith alleges that to avoid being hit by Defendant Smith.Id. ¶ 70). After this interaction, Hunt spoke to Callahan over the phone and expressed her concern about the hostile environment that Smith created. (Id. ¶ 72). Hunt also expressed that she would not be successful in her job if Smith continued to supervise her and asked whether Callahan would transfer her to a different supervisor. (Id. ¶¶ 7273). Callahan refused to transfer Hunt to a different supervisor. (Id. ¶ 73). On another occasion, on or around January 19, 2024, when Callahan called Hunt to advise her that more work needed to be done on one of the cases that was assigned to Hunt, Hunt could (Id. ¶ 80). Hunt felt so alone and unassisted by Smith that she called her Union to help her. (Id. ¶ 83). All the while, Smith continued to make unreasonable requests, including, for instance, requiring Hunt to provide reports for individuals without court dates, despite initially telling her not to do this. (Id. ¶ 84). In addition to unreasonable demands, Hunt 

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 by telling colleagues Id. ¶¶ 8587). Indeed, Hunt alleges that [i]n addition to the bullying, Defendant Smith was intentionally and maliciously trying to hurt Ms. Hunt with this smear campaignId. ¶ 87). Such instances of Smith bullying Hunt or making unreasonable demands only continued. (Id. ¶¶ 89101). On another occasion, Hunt confided in a colleague that she was tired of being mistreated by [Smith] . . . [and] that she was suffering a mental breakdown as a result.Id. ¶ 104). That day, Hunt received permission to leave work early because of how distraught she was and immediately contacted her therapist. (Id.). On January 22, 2024, Hunt finally voiced her concerns to Ronnie Coleman, a Regional Administrator at DPSCS, about how Smith and Callahan were treating her. (Id. ¶ 88). Coleman said she would speak with Smith and Callahan to correct the issues, but nothing changed. (Id.). Later, on March 25, 2024, Hunt again spoke with Coleman about Smith. (Id. ¶ 106). Coleman asked Hunt to memorialize her complaint in writing and to send it to him. (Id.). Coleman notified Hunt that, effective immediately, she would transfer Hunt to Field Supervisor I Kari WiechelId. ¶¶ 47, 106). Hunt -Id. ¶ Id.). Hunt acknowledges that the Department investigated the workplace environment at the Elkton field office. (Id. ¶ 108). To that end, on April 11, 2024, Robert Hudley and Veronica Clerk, Regional Supervisors at DPSCS, interviewed Hunt about her experiences but no one ever provided Hunt with updates regarding the investigation. (Id. ¶¶ 108109). 

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Even after others got involved, however, Hunt alleges that the differential treatment continued. For example, Hunt alleges that a new agent, Erin Tracy, a white Caucasian female, eventually started working at the Elkton field office with Hunt. (Id. ¶ 110). Hunt s a white Caucasian female, Ms. Tracy was treated differently from her darker-skinned Afrgraduation, assisted Ms. Tracy in writing reports, went to court for her, was more hands-on with Ms. Tracy, and gave her easier and less time-consuming workloadsId. ¶ 115). Hunt alleges that other white Caucasian agents received either less cases or no cases after graduating from training, even though Smith assigned Hunt sixty cases. (Id. ¶¶ 116117). Smith also singled Hunt out by limiting her ability to work in the office past 7 p.m., which would prevent Hunt from receiving flextime pay. (See id. ¶¶ 130131). On or around August 2024, Hunt began communicating with Lavonya Moody, a Senior Advisor at DPSCS, about her complaints regarding Smith and Callahan. (Id. ¶ 135). On August 22, 2024, Hunt filed a Complaint with the Office of Fair Practice and Inclusion Equal Employment Opportunity Unit, alleging that she was the subject of workplace bullying and unfair employment practice. (Id. ¶ 139). On August 30, 2024, Callahan sent an email to the office indicating that Defendant Smith would be reassigned to the Bel Air Office effective September 11, 2024. (Id. ¶ 140). Hunt alleges that the Office of Fair Practice and Inclusion determined there was sufficient evidence to support a probable cause finding that Hunt was subjected to workplace bullying and unfair employment practices, but that Smith and Callahan remain employed and in contact with Hunt. (Id. ¶¶ 143146). 

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B. Procedural History Hunt filed a charge of discrimination with the Equal Employment Opportunity ¶¶ 911).2 The EEOC issued a Right to Sue Letter on May 19, 2025. (Id. ¶ 10). On August 18, 2025, Hunt filed a Complaint against Danielle Callahan, Carolyn Scruggs, and Kerri Smith. (ECF No. 1). The eight-count Complaint alleges discrimination based on race and color in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e (Count I); retaliation in violation of 42 U.S.C. § 1981 (Count II); racial discrimination in violation of 42 U.S.C. § 1981 (Count III); retaliation in violation of Title VII (Count IV); harassment, discrimination, and retaliation in violation § 20-601, et seq. (Counts V, VI); negligence (Count VII); and negligent supervision (Count VIII). (Compl. ¶¶ 152-241). On December 29, 2025, Defendants filed a Motion to Dismiss. (ECF No. 22). Hunt filed her Opposition on March 2, 2026. (ECF No. 26). On March 27, 2026, Defendants filed a Reply. (ECF No. 29). II. DISCUSSION A. Standard of Review King v. Rubenstein, 825 F.3d 206, 214 (4th Cir. 2016) (quoting Edwards v. City of Goldsboro, 178 F.3d 231, 243 (4th Cir. 1999)). A complaint fails to state a claim if it 2 Hunt does not specify the date of the EEOC Charge. 

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Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twomblypleads factual content that allows the court to draw the reasonable inference that the Id. (citing Twombly, 550 U.S. at 556). Id. (citing Twombly, 550 U.S. at 555). Though the plaintiff is not required to forecast evidence to prove the elements of the claim, the complaint must allege sufficient facts to establish each element. Goss v. Bank of Am., N.A., 917 F.Supp.2d 445, 449 (D.Md. 2013) (quoting Walters v. McMahen, 684 F.3d 435, 439 (4th Cir. 2012)), In considering a Rule 12(b)(6) motion, a court must examine the complaint as a whole, consider the factual allegations in the complaint as true, and construe the factual allegations in the light most favorable to the plaintiff. Albright v. Oliver, 510 U.S. 266, 268 (1994); , 407 F.3d 266, 268 (4th Cir. 2005) (citing Scheuer v. Rhodes, 416 U.S. 232, 236 (1974)). But the court need not accept unsupported or conclusory factual allegations devoid of any reference to actual events, United Black Firefighters v. Hirst, 604 F.2d 844, 847 (4th Cir. 1979), or legal conclusions couched as factual allegations, Iqbal, 556 U.S. at 678. challenge, asserting that the allegations in the complaint are insufficient to establish subject 

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Hasley v. Ward Mfg., LLC, No. RDB-13-1607, 2014 WL 3368050, at *1 (D.Md. July 8, 2014) (quoting Kerns v. United States, 585 F.3d 187, 192 (4th Cir. 2009)). When a defendant raises a facial challenge, the Court affords the plaintiff Kerns, 585 F.3d at 192 (quoting Adams v. Bain, 697 F.2d 1213, 1219 (4th Cir. 1982)). As such, the Court takes the facts alleged in the complaint as true and denies the motion if the complaint alleges sufficient facts to invoke subject-matter jurisdiction. B. Analysis 1. Immunity or other statutory bars. (Mot. at 1316, ECF No. 22-2).3 Defendants assert that they are entitled to immunity under the Eleventh Amendment 1981. (Id.). The Court agrees that the Eleventh Amendment and its actors in their official capacity. (Id. at 16); see Perkins v. Univ. of Md., Balt Sch. of Nursing, No. RDB-24-1688, 2025 WL 1371486, at *5 (D.Md. May 12, 2025) MFEPA claims [against an instrumentality or arm of state] are barred by sovereign immunity under the Eleventh Amendment.; Just Puppies, Inc. v. Frosh, 438 F.Supp.3d their official capacity are also entitled to 3 

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 official but rather is a suit against the , 491 U.S. 58, 70 (1989)). 1981 claims against the Department and the individual Defendants in their official capacities are also barred because guaranteed in § 198 1983 violation. (Mot. at 13Reply Supp. Mot. Dismiss at 4, ECF No. 29 (quoting Dennis v. County of Fairfax, 55 F.3d 151, 156 (4th Cir. 1995))). Further, the Court notes, and Hunt does not contest, that Title VII claims cannot be brought against individually named defendants. (See at 1, ECF No. 26 -capacity Title VII liability. . . . To the extent Defendants seek dismissal of individual-capacity Title VII claims against Ms. Smith, Ms. Callahan, or Secretary Scruggs, Plaintiff does not oppose )). Callahan in their personal capacities. See Brown v. Town of Capitol Heights, No. 25-1336-TDC, 2026 WL 472821, at *4 (D.Md. Feb. 19, 2026) As a preliminary matter, the Court will dismiss the . . . Title VII and MFEPA claims for employment discrimination . . . against the Individual Defendants, because Title VII and MFEPA claims must be asserted against the employer . . . and may not be asserted against supervisors or managers in their individual capacities. Even so, however, none of these limitations categorically bar Hunt from proceeding with claims under 42 U.S.C. § 1981 against Smith and Callahan in their personal capacities. 

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See Windsor v. Bd. of Educ. of Prince Georges Cnty., No. TDC-14-2287, 2016 WL 4939294, at *14 (D.Md. Sep. 13, 2016) § 1981 claims as to the claims against the Board and the Individual Defendants in their official capacities, but den[ying the Motion] as to the claims against the Individual Defendants in their personal capacities. In any event, the Courtanalysis under Title VII, MFEPA, and 42 U.S.C. § 1981 is the same. See Nana-Akua Takyiwaa Shalom v. Payless Shoesource Worldwide, Inc., [M]FEPA claims of discrimination are ; Sanders v. Tikras Tech. Sols. Corp., 725 F.Appx 228, 229 (4th Cir. 2018) The McDonnell Douglas framework was initially developed for Title VII discrimination cases but since the McDonnell Douglas decision, the framework has been held to apply in discrimination cases arising under § 1981 and in retaliation cases under Title VII and § 1981 (citation omitted)); Anthony v. United Airlines, Inc., No. 24-2128, 2026 WL 35963, at *2 n.2 (4th Cir. Jan. 6, 2026) There is no dispute that all of Appellants retaliation claims [under] 42 U.S.C. § 1981 and Title VII can be considered togetherwithout prejudice MFEPA defendants and her 42 U.S.C. § 1981 claims against the Department and Smith and 

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Callahan in their official capacities but will otherwise analyze Hunt Title VII and 42 U.S.C. § 1981 claims below.4 2. Discrimination The Court will next Title VII prohibits an employer from discriminating against employees due to race, color, religion, sex, or national origin. 42 U.S.C. § 2000e-a burden-Netter v. Barnes, 908 F.3d 932, 938 (4th Cir. 2018) (quoting Foster v. Univ. of Md.-E. Shore, 787 F.3d 243, 249 (4th Cir. 2015)). The Complaint does not include allegations of direct evidence of discrimination. See Cole v. Fam. Dollar Stores of Md., Inc.(quoting Taylor v. Va. Union Univ., 193 F.3d 219, 232 (4th Cir. 1999)). Accordingly, the Court will evaluate claim under the burden-shifting framework first articulated by the Supreme Court in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973). 4 Hunt names Carolyn Scruggs, Secretary of the Department of Public Safety and Correctional Services as a defendant and therefore Huntunder Title VII may proceed. See Simmons v. Shalala, 946 F. Supp. 415, 418 (D. Md. action claiming employment discrimination.) 

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To establish a discrimination or retaliation claim under the McDonnell Douglas burden-shifting framework, Hunt must eventually put forth a prima facie case by establishing that: (1) [s]he belongs to a protected class; (2) [s]he suffered an adverse employment action; (3) at the time of the adverse action, [s]he was performing h[er] job at a level that met h[er] . . . ; and (4) [s]he was rejected [or disciplined] under circumstances giving rise to an inference of unlawful discrimination. See Adams v. Trs. of the Univ. of N.C.-Wilmington, 640 F.3d 550, 558 (4th Cir. 2011) (citing Taylor, 193 F.3d at 230). The precise formulation of the required prima facie McDonnell Douglas, 411 U.S. at 802 Swierkiewicz v. Sorema N. A., 534 U.S. 506, 512 (2002) (quoting Furnco Constr. Corp. v. Waters, 438 U.S. 567, 577 (1978)). If Hunt succeeds in establishing a prima facie case, the -discriminatory reason for its Mackey v. Shalala, 360 F.3d 463, 468 (4th Cir. 2004) (quoting Evans v. Tech. Applications Serv. Co., 80 F.3d 959 (4th Cir. 1996))burden shifts back to the employee to show that the given reason was just a pretext for Id. The Court is mindful that a Title VII plaintiff need not satisfy all the elements set forth above to survive a motion to dismiss. See Swierkiewiczfacie case under McDonnell Douglas, however, is an evidentiary standard, not a pleading accord , No. ELH-20-3523, 2021 

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 Bing v. Brivo Sys., LLC, 959 F.3d 605, 617 (4th Cir. 2020) (quoting Coleman v. Md. Ct. of Appeals, 626 F.3d 187, 190 (4th Cir. 2010)), cert. denied, 141 S.Ct. 1376 (2021). Thus, the plaintiff must generally show that the employer took adverse action . v. Burdine, 450 U.S. 248, 253 (1981); Adams, 640 F.3d at 558 (citing Taylor, 193 F.3d at 230). This requirement can be met by showing -situated employees outside the protected class received more favorable White v. BFI Waste Servs., LLC, 375 F.3d 288, 295 (4th Cir. 2004). Hunt has adequately alleged discrimination. See Strothers v. City of Laurel, Md., 895 F.3d 317, 330see also Woods v. City of Greensboro, 855 F.3d evidence of a general pattern of . . . discrimination in the practices of Guirkin v. CMH Physician Servs., LLC, No. 3:20cv59, 2020 WL 6829769, at *7 n.13 themselves prove discriminatory animus, the totality of circumstances surrounding his termination gives rise to the inference that [plaintiff] was fired, at least in part, because of 

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Here, the only element that Defendants contest is the second element regarding adverse action. (Mot. at 810). That is, Defendants insist that Hunt did not suffer an adverse employment action because she was not demoted, her pay did not decrease, nor were her responsibilities taken away. (Id.). The Court, however, rejects such a narrow view of what constitutes adverse action. A Roberts v. Glenn Indus. Grp., Inc., 998 F.3d 111, 122 (4th Cir. 2021) (quoting Chang Lim v. Azar, 310 F.Supp.3d 588, 601 (D.Md. 2018)). Hunt takes issue with multiple conditions of her employment, including, for example: (1) the disproportionately high caseload that Smith assigned her as compared to her alleged-similarly-situated comparators; (2) Smith manipulating her schedule such that Hunt was no longer able to earn flex time in contrast to her alleged-similarly-situated comparators; and (3) duty schedule to remove the experienced partner who worked with Hunt, leaving Hunt as the only agent to fully able process intakes, and thereby increasing her workload. (Compl. ¶¶ 3761, 124, 130161). The Court is satisfied that Hunt adequately alleges adverse action because, viewing the facts in the light most favorable to Hunt, all the employment decisions she contests appear to have worsened the conditions of her employment. (Id.). While Defendants may ultimately prevail in proving that these decisions were not made on the basis of a protected class, that determination is not before the Court at the 12(b)(6) stage. Accordingly, the Title VII and 42 U.S.C. § 1981. 

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3. Retaliation Hunt also brings claims for retaliation. (Compl. ¶¶ 165172, 18192). Title VII prohibits an employer from retaliating against an employee who exercises his Title VII rights. Hart v. Lew, 973 F.Supp.2d 561, 582 (D.Md. 2013). To establish a prima facie claim of retaliation under Title VII, Hunt [she] engaged in protected activity, that [her employer] took adverse action against [her], and that a causal relationship existed Id. (quoting Price v. Thompson, 380 F.3d 209, 212 (4th Cir. 2011)). If she succeeds in establishing a prima facie case, the McDonnell Douglas framework applies, just as it does for a discrimination claim: a defendant offers a non-discriminatory explanation for the adverse action, the plaintiff bearId. (citation modified). discriminate against any of [its] employees . . . because he has opposed any practice made an unlawful practice by this subchapter, or because he has made a charge, testified, assisted, or participated in any manner in an investigation, proceeding, or hearing under this either opposing a practice prohibited under Title VII ([under] the opposition clause) or making a charge, testifying, assisting, or participating in an investigation, proceeding, or Pitter v. Cmty. Imaging Partners, Inc.

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to encompass informal protests, such as voicing complaints to employers or using an employerId. at 396 (quoting Armstrong v. Index Journal Co., 647 F.2d 441, 448 (4th Cir. 1981). The Court finds that Hunt has stated a prima facie case of retaliation. First, around January 17, 2024, Hunt alleges that she engaged in at least one act of protected activity by meeting with Callahan and explaining she was concerned about the hostile environment created by Defendant Smith and that Ms. Hunt did not feel as if she would be successful in her job if she continued to be supervised and under the tutelage of Defendant Smith. (Compl. ¶ 72). Hunt asked Callahan to transfer her to a different supervisor, but Callahan refused. (Id. ¶ 73). Hunt also met directly with Smith and voiced her concerns to her as well. (Id. ¶¶ 5052). Second, Defendants took adverse action against Hunt by worsening her employment conditions, including, for example, individuals without court dates despite initially being told that such work was unnecessary, despite other similarly situated comparators allegedly not having this type of workload. (Id. ¶¶ 8384, 160). Third, Hunt alleges that at least some of these actions occurred a few days and hostile behavior, which, at this stage, is sufficient to allege causal connection. (Id. ¶¶ 7784); see Dowe v. Total Action Against Poverty in Roanoke Valley, 145 F.3d 653, 657 (4th Cir. 1998) vidence that the alleged adverse action occurred shortly after the 

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employer became aware of the protected activity is sufficient to satisf[y] the less onerous burden of making a prima facie case of causa[tion]. Hunt has pleaded a prima facie case of retaliation because she has alleged all three elements. See Hart, 973 F.Supp.2d at 582. Under the McDonnell-Douglas framework, the burden then shifts to Defendants to offer a non-discriminatory explanation for the adverse action. See id. Defendants proffer no explanation for the adverse decisions because they assert that these conditions were not materially adverse. (Mot. at 810). Because the Court At this stage, the Court finds that Hunt inference that [the employer took an adverse employment action against the plaintiff] Barbour v. Garland, 105 F.4th 579, 590 (4th Cir. 2024) (quoting Holloway v. Maryland, 32 F.4th 293, 300 (4th Cir. 2022)). The . . . will survive a Rule 12(b)(6) Id. (quoting Woods v. City of Greensboro, 855 F.3d 639, 649 (4th Cir. 2017)). Here, Defendants nondiscriminatory and non-pretextual explanation that [] renders [HuntId. Accordingly, Def Motion will be denied as to the retaliation claim under Title VII and 42 U.S.C. § 1981. 4. Hostile Work Environment To the extent Hunt seeks to allege a hostile work environment claim, such a claim fails to pass 12(b)(6) muster. To state a hostile work environment claim, a plaintiff must 

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plead that there employment and to create an abusive work environment; and (4) which is imputable to the Boyer-Liberto v. Fontainebleau Corp., 786 F.3d 264, 277 (4th Cir. 2015) (quoting Okoli v. City of Baltimore, 648 F.3d 216, 220 (4th Cir. 2011)). A hostile Harris v. Forklift Sys., Inc., 510 U.S. 17, 21 (1993) (citation omitted). In determining whether the offending conduct was sufficiently severe or pervasive, (3) whether it is physically threatening or humiliating, or a mere offensive utterance; and Whittaker , Inc., No. DKC 14-2483, 2016 WL 429963, at *4 (D.Md. Feb. 4, 2016) (quoting Smith v. First Union Nat. Bank, 202 F.3d 234, 242 (4th Cir. 2000)). Here, she alleges that during one meeting that she had with Smith, face that she had to take a step back to avoid being hit by Defendant SmithSee Compl. ¶¶ 69of physical harm or perceived threat of harm. Even so, while deeply regrettable, the Court agrees that [i]ntermittent acts of harassment are insufficient to establish that a hostile work environment is severe or pervasive.citing Greene v. A. Duie Pyle, Inc., 371 

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F.Supp.2d 759, 76263 (D.Md. 2005))). environment claims to proceed where the discriminatory abuse is near constant, oftentimes of a violent or threatening nature, or has impacted the employeeTawwaab v. Va. Linen Serv., Inc., 729 F.Supp.2d 757, 777 (D.Md. 2010). The Fourth Perkins , 936 F.3d 196, 208 (4th Cir. 2019) Id. (quoting Sunbelt, 521 F.3d at 31516). That is the case here: Smith does not allege abusive discriminatory conduct that is sufficiently severe. Tawwaab, 729 F.Supp.2d at 777. While 148), the conduct alleged here [the] high of pleading a hostile work environment claim. Perkins, 936 F.3d at 208 (quoting Sunbelt, 521 F.3d at 315). Accordingly, claims for hostile work environment will be dismissed. 5. Negligence and Negligent Supervision Lastly, Hunt alleges claims of negligence and negligent supervision. (Compl.¶¶ 218241). Such claims may be predicated only on common law causes of action. Greenan v. Bd. of Educ. of Worcester Cnty., 783 F.Supp.2d 782, 791 (D.Md. 2011). -

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Id. In other words, a Hurley v. Howard Cnty D of Police, No. CJC-25-1498, 2026 WL 864078, at *17 (D.Md. Mar. 30, 2026) . Here, claims arise exclusively from statutorily prohibited employment-related conduct, and not any common law cause of action. (Compl. ¶¶ 12151). Hunt does not address, much less dispute, Therefore, Counts VII and VIII will be dismissed. III. CONCLUSION For the foregoing reasons, the Court will grant the Motion to Dismiss in part and deny it in part (ECF No. 22). Defendants shall answer the remaining counts of the Complaint in accordance with the Local Rules and Federal Rules of Civil Procedure. A separate Order follows. Entered this 29th day of May, 2026. /s/ George L. Russell, III Chief United States District Judge 

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