Unreported / Non-Citable
Background
Khoja Sohil Samadi, who represents himself, sued his former employer, Amazon.com Services, LLC, in Sacramento County Superior Court, seeking $37 million. The federal court called the complaint sparsely detailed and hard to follow. He alleged that a large box landed on his foot at work and that medical care was then denied. He also alleged that a manager harassed him at a San Francisco delivery station, that he reported the harassment to higher-level management, and that after a transfer to Elk Grove he was fired within a week on a false accusation. The complaint named two managers, and the court noted it was unclear whether he accused more than one person. His mother allegedly was fired by Amazon after requesting medical and disability accommodations, and he suggested Amazon fired him to harm the family financially. These are allegations only; the court made no findings on them.
After receiving a right-to-sue notice on April 16, 2026, Samadi filed suit on June 15, 2026. Amazon removed the case to the Eastern District of California on diversity grounds and moved to dismiss six claims: negligence, wrongful termination in violation of public policy, and four California Fair Employment and Housing Act (FEHA) theories (discrimination, harassment, retaliation, and failure to prevent). Amazon also sought to strike punitive damages. After Samadi missed the original opposition deadline and the court extended it, the court vacated the hearing and decided the motion on the papers.
The Court’s Holding
Magistrate Judge Carolyn K. Delaney granted the motion and dismissed the complaint with leave to amend. She treated the claims as effectively abandoned because Samadi's opposition did not defend them and instead offered new claims and facts, and she held in the alternative that each claim failed. Negligence was a catch-all recital without facts showing duty, breach, or causation. Wrongful termination identified no public policy grounded in a statute, regulation, or constitutional provision. The theory based on his mother's lawsuit was vague and speculative, and the claim also depended on the deficient FEHA claims.
The FEHA discrimination claim alleged an adverse action, the termination, but not protected-class membership, satisfactory performance, or any link between the harassment and the firing. The harassment claim said only that a manager harassed him every day until he complained. It lacked a protected group, a tie to that group, and specifics, and details added in the opposition, such as being called a snitch, could not amend the complaint. The retaliation claim, construed as arising under FEHA because Samadi did not contest that reading, lacked an alleged protected activity and a causal link to the firing. The court dismissed the mother's-lawsuit retaliation theory on its own, noting that Samadi's allegations drew from his connection to her suit, though Amazon had not separately moved on it. Failure to prevent was derivative, and the court did not reach punitive damages.
The dismissal is not a final judgment. Samadi has 30 days to file a First Amended Complaint that is complete in itself under Local Rule 220 and cures the identified defects rather than adding unrelated claims. If he does not, the order says a recommendation that the action be dismissed will follow.
Key Takeaways
- Labels and catch-all recitals do not satisfy Rule 12(b)(6); even a self-represented plaintiff must plead facts supporting each element of every claim.
- A plaintiff who does not defend challenged claims in an opposition brief risks having them treated as abandoned.
- Facts first raised in an opposition brief cannot substitute for allegations in the complaint itself.
- FEHA discrimination and harassment claims must allege protected-class status and a connection to it, and retaliation requires an alleged protected activity and a causal link to the adverse action.
- A failure-to-prevent claim falls when the underlying FEHA claims are not adequately pleaded.
Why It Matters
This is a trial-level order on a motion to dismiss. It is not a precedential ruling and decides no claim on the merits. It shows how a federal court in California applies the basic elements of FEHA and public-policy termination claims to a thin pro se complaint while still permitting amendment.
Still open is whether Samadi can plead facts, including protected status and a causal link to his firing, that support any claim. Punitive damages are undecided, and the only stated consequence of not amending is a recommendation of dismissal.