The U.S. Court of Appeals for the Eleventh Circuit affirmed the dismissal of employment discrimination claims brought by Valerie Lowery against Jefferson County Racing Association, concluding that her pro se complaint failed to state a claim under federal civil rights laws.
In a per curiam opinion filed Jan. 15, the three-judge panel upheld the U.S. District Court for the Northern District of Alabama's decision to dismiss Lowery's complaint for failure to state a claim. The case, *Valerie Lowery v. Jefferson County Racing Association* (11th Cir. 2026), involved allegations of race discrimination, disability discrimination, and retaliation under Title VII of the Civil Rights Act of 1964 and the Americans with Disabilities Act.
According to the operative amended complaint, Lowery, who is Black, suffers from knee problems that cause her to limp. The Association hired her to work in customer service, a role that required standing and walking. When a supervisor noticed her mobility issues, the Association initially permitted accommodations for her condition.
Lowery alleged that the Association violated Title VII by treating her worse than similarly situated employees of different races. She also claimed the company failed to accommodate her disability under the ADA and retaliated against her under both statutes after she argued with her supervisor, allegedly moving her to a worse position.
On appeal, Lowery argued that she had successfully stated claims under federal anti-discrimination laws. She contended that her complaint adequately pleaded race discrimination under Title VII because she alleged differential treatment compared to employees of other races. She also asserted that she stated a retaliation claim because the Association allegedly moved her to an inferior role following her dispute with a supervisor.
Regarding her disability claims, Lowery maintained that whether the Association failed to accommodate her knee problems was a factual issue that should survive dismissal at the pleading stage.
The Eleventh Circuit panel, comprised of Circuit Judges Brasher, Anderson, and Wilson, rejected these arguments after careful review. The court applied the standard that pro se pleadings must be construed liberally, but even under this lenient standard, found that Lowery's complaint did not meet the minimum requirements to state viable federal claims.
For Title VII race discrimination claims, plaintiffs must generally show they were treated differently than similarly situated employees outside their protected class under comparable circumstances. The court's affirmance suggests that Lowery's allegations, even when viewed in the light most favorable to her as the non-moving party, failed to establish the necessary elements for her discrimination claims.
Similarly, for ADA claims, employers have a duty to provide reasonable accommodations for qualified employees with disabilities, unless doing so would cause undue hardship. Retaliation claims under both statutes require showing that an employee engaged in protected activity and suffered adverse employment action as a result.
The appeals court's decision reflects the challenging standard plaintiffs face when bringing employment discrimination claims, particularly when representing themselves without counsel. Pro se litigants, while given some leeway in pleading standards, must still meet fundamental legal requirements to survive motions to dismiss.
The case was designated for the non-argument calendar, indicating the court determined oral arguments were unnecessary for resolution. The opinion is marked "not for publication," meaning it will not serve as binding precedent but may be cited for its persuasive value.
Jefferson County Racing Association operates in Alabama's racing industry. Employment discrimination cases in this sector can involve unique workplace challenges, including physical job requirements that may conflict with disability accommodations and diverse workforce dynamics that can give rise to discrimination claims.
The Northern District of Alabama initially heard the case under docket number 2:24-cv-01217-GMB before Lowery appealed to the Eleventh Circuit. District courts regularly handle employment discrimination cases as a significant portion of federal civil rights litigation.
The Eleventh Circuit's jurisdiction covers Alabama, Florida, and Georgia, and the court frequently addresses employment law issues affecting workers throughout the Southeast. This decision adds to the circuit's body of precedent regarding pleading standards for discrimination claims.
For future plaintiffs considering similar claims, this case underscores the importance of detailed factual allegations that clearly connect discriminatory conduct to protected characteristics and adverse employment actions. While pro se plaintiffs receive some accommodation in pleading requirements, courts still expect complaints to meet basic legal standards for stating cognizable claims under federal anti-discrimination statutes.
The affirmance also highlights the challenges facing employees with disabilities in securing workplace accommodations and protection from retaliation. Employers in Alabama and across the Eleventh Circuit continue to have obligations under the ADA to engage in good faith accommodation discussions with qualified employees who have disabilities.