In Stephens v. Harcros Chemicals, Inc., 2026 WL 3255504 (8th Cir. Oct. 29, 2026), the U.S. Court of Appeals for the Eighth Circuit affirmed the lower court’s judgment dismissing plaintiff’s race discrimination claims under Title VII of the Civil Rights Act of 1964 and 42 U.S.C. § 1981.
From the decision:
To state a claim for racial discrimination under Title VII and 42 U.S.C. § 1981, Stephens must allege: (1) he was a member of a protected class; (2) discriminatory intent by the defendants; (3) he engaged in protected conduct; and (4) the defendants interfered with that conduct. Yang v. Robert Half Int’l, Inc., 79 F.4th 949, 962, 964 (8th Cir. 2023). At the pleading stage, a plaintiff must plead sufficient factual allegations to plausibly support each element of a claim. Colson v. Hennepin Cnty., 169 F.4th 773, 777 (8th Cir. 2026). While a court must accept a complaint’s allegations as true, “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Ashcroft v. Iqbal, 556 U.S. 662, 678, 129 S.Ct. 1937, 173 L.Ed.2d 868 (2009).
Stephens alleges in his complaint that Harcros discriminated against him “on the basis of his race when it failed to conduct a thorough investigation of his claim of a false-positive drug test and withdrew the offer of employment and hired a person outside of the protected class that was less qualified.” Stephens does not further elaborate on the individual purportedly hired by Harcros or provide other factual support for discriminatory intent. As for i3Logix, he alleges the company “intentionally misrepresented” his explanation that he used a hemp product that could have caused a false-positive for marijuana.
Stephens’s complaint contains conclusory statements and a “threadbare recitation” of the elements, which fails to satisfy the plausibility standard. Similarly, Stephens makes no mention of racial animus at all against i3Logix. The district court did not err in dismissing Stephens’s racial discrimination claim against Harcros and i3Logix.
Accordingly, dismissal was warranted.