莫曼伊诉阿拉巴马大学伯明翰分校案

On April 15, 2024, Tamika Momanyi, a graduate student and employee at the University of Alabama at Birmingham (UAB), filed a pro se complaint against the university. She alleged that after disclosing her anxiety disorder and requesting accommodations, she faced retaliation, hostility, unfair academic evaluations, and was placed on administrative leave. Her second amended complaint included nine causes of action under the Americans with Disabilities Act (ADA) and the Fourteenth Amendment. UAB moved to dismiss all claims. On December 4, 2024, Magistrate Judge Gray M. Borden granted the motion to dismiss and denied Momanyi's motions to amend.

The court granted the Board's motion to dismiss all of Momanyi's claims with prejudice and denied her motions for leave to amend. The court held that Title I claims were barred by Eleventh Amendment immunity, Title II claims lacked sufficient factual support, and Fourteenth Amendment claims were not actionable. The case was concluded in the defendant's favor.

The central dispute was whether the Board of Trustees, as an arm of the state, was immune from Momanyi's ADA claims under the Eleventh Amendment. For Title I claims, the court found sovereign immunity barred suit. For Title II claims, the court found Momanyi failed to plausibly allege she was denied meaningful access to educational programs or services. Her Fourteenth Amendment claims were dismissed as the Amendment does not provide a private right of action against state entities.

The case reaffirmed the broad protection of state sovereign immunity under the Eleventh Amendment, particularly in ADA Title I claims against public universities. It highlighted the stringent pleading standards required for pro se plaintiffs in federal court, especially regarding disability discrimination and retaliation claims. The ruling also underscored the difficulty of bringing Fourteenth Amendment claims directly against state entities without proceeding under 42 U.S.C. § 1983. The decision may deter similar lawsuits against public universities in Alabama and reinforces the legal barriers faced by pro se litigants in employment discrimination cases.