UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
FORT LAUDERDALE DIVISION
BOYD JOHNSON,
Plaintiff,
v.
Case No.: 0:22-cv-60884-KMM
PUBLIX SUPER MARKETS, INC.,
IRBY, MARK R., PHILLIPS, DAVID P.
METZ, MERRIANN M., JONES, SR.,
RANDALL T.,
Defendants.
______________________________________/
MOTION TO DISMISS PLAINTIFF’S VERIFIED COMPLAINT
Defendant, Publix Super Markets, Inc. (“Publix”), by and through its undersigned counsel,
and under Rule 12(b)(6) of the Federal Rules of Civil Procedure, respectfully moves this
Honorable Court to dismiss the claims in the Verified Complaint of Boyd Johnson, as to all
parties—served and unserved—for failure to state a claim upon which relief can be granted.
Johnson alleges Publix (and the unserved defendants)1
discriminated against him based on
his race in violation of (i) Title II of the Civil Rights Act of 1964, as amended, 42 U.S.C. §2000a,
et seq. (“Title II”); (ii) Florida Civil Rights Act, FLA. STAT. §760, et seq. (“FCRA”); and (iii) Palm
Beach Municipal Code. However, all claims in Johnson’s Complaint are time-barred because
Johnson filed them outside of the applicable limitation periods. Further, for purposes of Title II
and the FCRA, Publix does not constitute a “place of public accommodation.” Johnson cannot
correct these fatal flaws by amendment of his pleading. Therefore, Johnson’s claims fail as a matter
1
The unserved defendants are officers and directors of Publix Super Markets, Inc., and are not
alleged to have engaged in an individual conduct. Rather, the claims against these unserved
defendants arise solely through the claim against corporate defendant, Publix Super Markets,
Inc.
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of law, and this Honorable Court should dismiss them with prejudice.
RELEVANT BACKGROUND
Johnson alleges early in the COVID-19 pandemic, on April 23, 2020, he shopped at a Boca
Raton, Florida Publix grocery store without wearing a mask. (See Exhibit 1, Johnson’s
Complaint2
, at ¶ 13). Even though Johnson acknowledges that companies like Publix faced the
ongoing COVID-19 pandemic, he alleges there were no company or state-mandated mask policies
as of April 2020 when this alleged discrimination occurred. (See id. ¶¶ 20-21).3
According to
Johnson, an unnamed Publix employee approached him while he was shopping, informing Johnson
he would not receive service if he were not wearing a mask. (Id. at ¶ 16). Johnson claims that when
he attempted to make a purchase later, an unnamed Caucasian employee declined to render service
to him. (Id. at ¶ 19). He further asserts that he observed other Caucasian customers similarly failing
to wear masks, but who received service. (Id. at ¶¶ 20-21). Johnson asserts that the basis for this
action was discrimination against African Americans. (See id. at ¶¶ 22, 30, 33-35). He claims he
suffered a denial of equal access to the facilities and services, along with lost time, and mental
anguish. (Id. at ¶¶ 38-40).
According to Johnson, on June 22, 2020, his attorneys contacted Publix about the alleged
discrimination during which Johnson claims a document entitled “Florida Commission on Human
Relations Public Accommodation Complaint” was sent to Publix by his then-counsel. (See id. at ¶
23, Exhibit “A”). This purported FCHR Public Accommodations Complaint is not attached to the
2
Plaintiff’s Complaint filed in the Circuit Court of the Seventeenth Judicial Circuit in and for
Broward County, Florida is attached as Exhibit 1 for ease of reference and the Court’s
convenience.
3
Although not dispositive to this Motion to Dismiss, Palm Beach County did have a mask
mandate for grocery stores to deal with the COVID-19 pandemic. (Palm Beach County,
Emergency Order 20-004, eff. April 13, 2020).
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Complaint. (See id. at Exhibit “A”). Rather, Exhibit “A” to Johnson’s Complaint is a settlement
demand letter dated May 21, 2020. (See id.). Johnson does not allege any administrative complaint
or Charge of Discrimination was filed with any federal, state, or local agency. (See generally
Exhibit 1.) He does not provide a copy of any filed administrative complaint or Charge of
Discrimination with any federal, state, or local agency. (See id.) And Johnson does not allege he
received a notice of rights to sue letter from any federal, state, or local agency or provided any
copy of such notice with his Complaint. (See id.)
4
But on April 14, 2022, Johnson, pro se, sued in state court. (Id.) In his Complaint, Johnson
alleged claims of public accommodation discrimination under Title II, the FCRA, and the
Municipal Code. (Id. at Counts I, III5
, and IV, pages 6-12). For the FCRA and the Municipal Code
claims, Johnson appears to assert, Publix is a “place of public accommodation”6
subject to the
applicable law.7
(See id. at ¶¶ 44, 54.) He, however, does not assert that Publix is a “place of public
accommodation” for the Title II claim. (See id. at ¶¶ 61-72.) Regardless, Johnson alleges no facts
demonstrating that Publix would qualify as a “place of public accommodation” under these laws.
4
While outside the four corners of the Complaint, as part of its Rule 11 due diligence in filing
this motion, Publix’s counsel conducted a good faith investigation and communication with
the appropriate agencies revealed no administrative charge or complaint filed by Johnson
against Publix.
5
There is no Count II. (See generally Exhibit 1).
6
Johnson uses the phrase “public accommodation” while the statutes and municipal code and
case law use the phrase “place of public accommodation.” For clarity, Publix uses the phrase
“place of public accommodation” throughout.
7
Johnson highlights a portion of the Municipal Code that defines a “public accommodation” as
including “a laundromat, dry-cleaner, bank, barber shop, beauty shop, travel service, shoe
repair service, funeral parlor, gas station, office of an accountant or lawyer, pharmacy,
insurance office, health care provider, hospital or other service establishment.” (See id. at ¶¶ 44
(citing PALM BEACH MUNI. CODE § 15-37(4)(f)) (emphasis in original)). Although it’s unclear
why Johnson highlights this provision, Publix would acknowledge that another subsection
defines a grocery store as a “place of public accommodation.” PALM BEACH MUNI. CODE § 15-
37(4)(e).
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Publix timely removed to this Court on May 10, 2022. (Dkt 1). Because Johnson fails to
state a claim upon which relief can be granted and it would be futile for him to amend, Publix
seeks to have his lawsuit dismissed with prejudice.
ARGUMENT
1. UNDER THE APPLICABLE STANDARD OF REVIEW, JOHNSON’S CLAIMS SHOULD BE
DISMISSED WITHOUT LEAVE TO AMEND.
Under Federal Rule of Civil Procedure 12(b)(6), a party may move to dismiss a complaint
for “failure to state a claim upon which relief can be granted.” To avoid dismissal under Rule
12(b)(6), “a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to
relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl.
Corp. v. Twombly, 550 U.S. 544, 570 (2007)). In evaluating the sufficiency of a complaint, a court
“must accept the facts pleaded as true and construe them in a light most favorable to [the] plaintiff
[ ].” Chaparro v. Carnival Corp., 693 F.3d 1333, 1337 (11th Cir. 2012); Quality Foods de Centro
Am., S.A. v. Latin Am. Agribusiness Dev. Corp., S.A., 711 F.2d 989, 994-95 (11th Cir. 1983). While
leave to amend should ordinarily be freely given, the Court may dismiss the complaint with
prejudice where any amendment would be futile. See Carvel v. Godley, 404 F. App’x 359, 361
(11th Cir. 2010) (citing Foman v. Davis, 371 U.S. 178, 182, (1962)). Here, accepting Johnson’s
factual allegations as true, Johnson’s Complaint does not contain sufficient factual matters to state
a claim for plausible relief. Pointedly, Johnson’s Complaint asserts claims either untimely because
he failed to exhaust his remedies, or for which the Boca Raton store has not been alleged to
constitute a “place of public accommodation” under Title II or the FCRA.
2. JOHNSON’S CLAIMS SHOULD BE DISMISSED AS UNTIMELY.
This Court should dismiss Johnson’s Claims because they are untimely under Title II, the
FCRA, and the Palm Beach Municipal Code. Each basis is addressed below.
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A. JOHNSON’S TITLE II CLAIM IS UNTIMELY BECAUSE HE FAILED TO PROVIDE
NOTICE TO A STATE OR LOCAL AGENCY BEFORE FILING SUIT.
This Court should dismiss Johnson’s Title II Claim as untimely because he failed to
complete the administrative prerequisites to filing a complaint. Title II requires that a Plaintiff
provide at least 30 days’ notice of an allegedly discriminatory behavior to an applicable state or
local authority before filing a complaint:
In the case of an alleged act or practice prohibited by this subchapter which occurs
in a State, or political subdivision of a State, which has a State or local law
prohibiting such act or practice and establishing or authorizing a State or local
authority to grant or seek relief from such practice or to institute criminal
proceedings with respect thereto upon receiving notice thereof, no civil action may
be brought under subsection (a) before the expiration of thirty days after written
notice of such alleged act or practice has been given to the appropriate State or local
authority by registered mail or in person, provided that the court may stay
proceedings in such civil action pending the termination of State or local
enforcement proceedings. . .
42 U.S.C. § 2000a-3(c). Both Florida and Palm Beach County law prohibit discrimination in places
of public accommodation based on race and other protected classes just like Title II. § 760.08,
FLA. STAT.; PALM BEACH MUNI.CODE § 15-57. The FCRA is enforced by the Florida Commission
on Human Relations (“FCHR”), and the Palm Beach Municipal Code by the Palm Beach Office
of Equal Opportunity. See §§ 760.021-06, FLA. STAT.; PALM BEACH MUNI. CODE § 15-38, 47.
Courts in the Eleventh Circuit, including courts in the Southern District of Florida, dismiss
claims where a plaintiff fails to exhaust remedies by providing notice. Strober v. Payless Rental
Car, 701 F. App’x 911, 912-913 (11th Cir. 2017); Brown v. Zaveri, 164 F. Supp. 2d 1354, 1360
(S.D. Fla. 2001); Zinman v. Nova Southeastern Univ., No. 21-CV-60723-RUIZ/STRAUSS, 2021
U.S. Dis. LEXIS 165341, at **14-16 (S.D. Fla. Aug. 30, 2021). In Strober, the Eleventh Circuit
held dismissal of plaintiff’s claim was appropriate where plaintiff failed to comply with Title II’s
notice requirements as plaintiff’s complaint did not allege that she had provided written notice of
her claim to the FCHR. 701 F. App’x at 912-913. In Brown, an African-American patron sued
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several entities for failing to be served at a McDonalds, which he claimed was due to unlawful
discrimination because of race but failed to notify the FCHR. 164 F. Supp. 2d at 1356-57. The
Brown Court dismissed the lawsuit because the patron hadn’t notified the FCHR within the 365-
day period to file a claim with the FCHR and that period expired. Id. at 1357.
Here, as in Strober and Brown, Johnson’s timing is not remotely close to Title II’s
requirements. It is true Johnson claims he sent an FCHR Public Accommodation Complaint to
Publix. (Exhibit 1, at ¶ 23). But importantly, there are no allegations in the Complaint that Johnson
submitted anything to the FCHR or the Palm Beach Office of Equal Opportunity before suing.
(See generally Exhibit 1). There is no evidence of a Public Accommodation Complaint, any
Charge of Discrimination, or any other notice being submitted to either a state or local agency.
(See id.).8
Amendment would be futile, as Johnson now cannot satisfy the requirements. The alleged
unlawful discrimination—which is denied—allegedly occurred on April 23, 2020–over 2 years
ago. The FCHR requires any notice of alleged unlawful discrimination to be submitted within 365
days of the alleged discrimination. § 760.11(1), FLA. STAT. As noted above, there is no allegation
or evidence that Johnson timely met this requirement—nor could he meet this requirement after
the fact. See Peters v. Cheval Golf & Athletic Club, LLC, 2002 U.S. Dist. LEXIS 3985 (M.D. Fla
Jan. 7, 2022) (granting summary judgment for defendant belatedly providing notice to FCHR more
than a year after the alleged incident of discrimination insufficient to maintain claim). Hence, the
Court should dismiss Johnson’s Title II claim with prejudice as time-barred.
8
As noted above, while outside the four corners of the Complaint, Publix’s counsel has
communicated with both the FCHR and the Palm Beach Office of Equal Opportunity, and
neither reported the filing of an administrative charge or complaint by Johnson against Publix.
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B. JOHNSON’S FCRA CLAIM SHOULD BE DISMISSED AS UNTIMELY.
Johnson’s FCRA claim is also untimely. A plaintiff’s exhaustion of his administrative
remedies is a jurisdictional prerequisite to filing a public accommodation action under the FCRA.
Sheely v. MRI Radiology Network, P.A., 505 F.3d 1173, 1205 (11th Cir. 2007); Ring v. Boca Ciega
Yacht Club, Inc., No. 8:19-cv-772-T-33JSS, 2019 U.S. Dist. LEXIS 193478, at *16 (M.D. Fla.
Nov. 7, 2019) (citing Jones v. Bank of America, 985 F. Supp. 2d 1320, 1324-25 (M.D. Fla. 2013);
Ring v. Boca Ciega Yacht Club, Inc., No. 8:19-cv-772-T-33JSS, 2019 U.S. Dist. LEXIS 193478,
at *16 (M.D. Fla. Nov. 7, 2019) Here, a complainant like Johnson must file a charge with the
FCHR within 365 days of the alleged violation. § 760.11(1), FLA. STAT. As alleged, the alleged
incident happened on April 23, 2020. Johnson claims he sent a “Florida Commission on Human
Relations Public Accommodation Complaints” addressed to Publix in June 2020. (See Exhibit 1
at ¶ 23). But, like previously noted, there is no allegation or evidence he submitted this Complaint
or any Charge of Discrimination to the FCHR or any agency within the 365-day period, or no later
than April 23, 2021. Because he did not, and cannot, meet this deadline, Johnson’s FCRA claim
should be dismissed for failing to exhaust remedies.
C. JOHNSON’S MUNICIPAL CODE CLAIM SHOULD BE DISMISSED AS UNTIMELY.
Johnson’s Municipal Code Claim should be dismissed for failing to meet the statutory
conditions to sue. As with Title II and the FCRA, the Palm Beach Municipal Code also prohibits
unlawful discrimination regarding “places of public accommodation,” including because of race.
See PALM BEACH MUNI. CODE § 15-57. The Palm Beach Municipal Code states that a civil
action can be initiated within 2 years. PALM BEACH MUNI. CODE § 15-56(a),(b). Yet, unlike Title
II or the FCRA, it does not on its face require an exhaustion of statutory conditions before suit
can be filed. See id. But, Florida courts hold a municipal code prohibiting discrimination in a
“place of public accommodation,” like Palm Beach’s, may not eliminate the FCRA statutory
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requirement to file an administrative complaint within 365 days of the alleged unlawful
discrimination. OC Food & Beverage LLC v. Orange County, No. 5D21-1061, 2022 Fla. App.
LEXIS 1762 (Fla. 5th DCA, Mar. 14, 2022).
In OC Food & Beverage, a restaurant challenged the Orange County Human Rights
Ordinance for conflicting with the FCRA. Id. at *2. The plaintiff sued the restaurant for sex
discrimination under the Orange County Ordinance, under that ordinance’s procedures for private
causes of action. Id. at *3. The Orange County Ordinance provided, like here, a private citizen
could sue pursuing no administrative remedies. Id. The restaurant argued the ordinance was
preempted by or otherwise conflicted with the FCRA. The trial court disagreed, concluding the
FCRA neither preempted nor conflicted with the ordinance; however, the appellate court overruled
this decision finding the ordinance conflicted with the FCRA, and thus the FCRA pre-conditions
of suit applied. Id. at *6. Specifically, the Florida Fifth District Court of Appeal observed that the
FCRA requires satisfaction of certain administrative conditions before a private individual can sue
for unlawful discrimination in places of public accommodation. Id. (citing §§ 760.08, 760.11, FLA.
STAT.). It pointed out that the Florida Supreme Court previously recognized the Florida
Legislature created this statutory scheme with a purpose. The Florida Legislature intended persons
who believed they had been subjected to discrimination to go through an administrative process
before suing, id. at *7 (citing Joshua v. City of Gainesville, 768 So. 2d 432, 436 (Fla. 2000)),
giving the FCHR an opportunity to investigate, obtain voluntary compliance, and promote
conciliation efforts outside of litigation. Id. (citing Sunbeam Television Corp. v. Mitzel, 83 So. 3d
865, 874 (Fla. 3d DCA 2012)).
The OC Beverage Court also observed under settled Florida law, municipalities like
Orange County have broad powers of local self-government under Florida law, but such powers
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cannot be inconsistent with state general law. Id. It further noted that in areas where both Florida
and the local government could legislate concurrently, a county could not enact an ordinance that
conflicted with a Florida statute. Id. (citing Orange County v. Singh, 268 So. 3d 668, 673 (Fla.
2019)). Under Florida law, a conflict exists when a local ordinance stands as an obstacle to the
execution of the Florida statute’s full purpose. Id. (citing Masone v. City of Aventura, 147 So. 3d
492, 495 (Fla. 2014)). And, importantly, a municipality may not authorize what the Florida
legislature has forbidden. Id. (citing Rinzler v. Carson, 262 So. 2d 661, 668 (Fla. 1972)).
Thus, the Fifth Circuit Court of Appeals concluded the local ordinance, nearly identical to
the Palm Beach County Ordinance plead in this case, explicitly allowing suit on a public
accommodations discrimination suit without exhausting remedies under the FCRA stood as an
obstacle to the execution of the purpose of the FCRA, id. at **7-8, holding the portion of the local
ordinance allowing suit without exhausting administrative remedies null and void as against
Florida law. Id. Here, there are no allegations nor evidence that Johnson submitted a Charge of
Discrimination to the Palm Beach Office of Equal Employment or the FCHR. Rather, Johnson has
simply sued, asserting a right to do so within two (2) years of the alleged act under the Municipal
Code without first exhausting administrative remedies. (See Exhibit 1 at ¶ 23). Like the Orange
County ordinance, the Palm Beach Municipal Code includes the same broad language as the
Orange County local ordinance and should be treated the same. Compare OC Beverage, 2022 Fla.
App. LEXIS 1762 at *3 with PALM BEACH MUNI. CODE § 15-56(a). While the Palm Beach
Municipal Code does not explicitly allow a suit without submitting an administrative charge, under
Florida law, an ordinance’s silence does not confer rights precluded by state law in the FCRA
requiring an administrative process. See OC Beverage, 2022 Fla. App. LEXIS 1762 at *7 (citing
Rinzler v. Carson, 262 So. 2d 661, 668 (Fla. 1972)). Thus, Johnson cannot assert his Municipal
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Code claim without first exhausting his administrative remedies; administrative remedies he fails
to allege (and cannot cure). Thus, Johnson’s Municipal Code claim should be dismissed.
3. JOHNSON’S TITLE II AND FCRA CLAIMS SHOULD ALSO BE DISMISSED BECAUSE THE
BOCA RATON STORE HAS NOT BEEN ALLEGED TO BE A “PLACE OF PUBLIC
ACCOMMODATION” UNDER TITLE II OR THE FCRA.
Johnson’s Title II and FCRA Claims should also be dismissed because Johnson has failed
to allege facts supporting Publix as a “place of public accommodation” under that law. Title II and
the FCRA entitle all persons “to the full and equal enjoyment of the goods, services, facilities,
privileges, advantages, and accommodations of any place of public accommodation [as defined by
Title II of this section].” 42 USC § 2000a; § 760.08, FLA. STAT. But, Title II and the FCRA only
applies to certain enumerated types of places. See 42 USC § 2000a(b); § 760.02(11), FLA. STAT.
Both Title II’s and the FCRA’s definition of a “place of public accommodation” does not explicitly
include retail establishments like grocery stores such as Publix:
[P]laces of public accommodation, lodgings, facilities principally engaged in selling
food for consumption on the premises, gasoline stations, places of exhibition or
entertainment, and other covered establishments. Each of these establishments
which serves the public is a place of public accommodation within the meaning of
this section:
* * *
(2) Any restaurant, cafeteria, lunchroom, lunch counter, soda fountain, or other
facility principally engaged in selling food for consumption on the premises,
including, but not limited to, any such facility located on the premises of any retail
establishment, or any gasoline station.
* * *
(4) Any establishment which is physically located within the premises of any
establishment otherwise covered by this subsection, or within the premises of which
is physically located any such covered establishment, and which holds itself out as
serving patrons of such covered establishment.
42 USC § 2000a(b)(2),(4); § 760.02(11)(b),(d), FLA. STAT. The FCRA is to be interpreted
consistently with federal law, and given their textual similarities, both the FCRA and Title II
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definitions of public accommodation are interpreted the same. State v. Jackson, 650 So. 2d 24, 27
(Fla. 1995) (observing “a long-standing rule of statutory construction in Florida recognizes that if
a state law is patterned after a federal law on the same subject, the Florida law will be accorded
the same construction as given to the federal act in the federal courts.”); Palm Beach Cty. Sch. Bd.
v. Wright, 217 So. 3d 163, 165 (Fla. 4th DCA 2017) (according FCRA construction with Title VII
case law); Byrd v. BT Foods, Inc., 26 So. 3d 600, 605 (Fla. 4th DCA 2009) (same with the ADA).
The congressional history of Title II indicates the definitional language was done
purposefully, with Congress intentionally excluding retail stores, food markets, and similar
establishments from the list of enumerated places of public accommodation in the Civil Rights
Act. See Newman v. Piggie Park Enterprises, Inc., 377 F. 2d 433, 436 (4th Cir. 1967) modified on
other grounds 390 U.S. 400 (1968) (citing 110 CONG. REC. 6533 (1954) (Remarks of Senator
Humphrey)). Congress had concluded when passing the Civil Rights Act that there was little—if
any—discrimination in those operations when the Civil Rights Act was passed. See id.; see also
Priddy v. Shopko Corp., 918 F. Supp. 358, 359 (D. Utah 1995).
With retail establishments, the key inquiry is whether the establishment is one principally
engaged in selling food for consumption on the premises or otherwise falls within the enumerated
establishments in Title II. See Priddy, 918 F. Supp. at 359. Courts routinely recognize a retail
grocery store or convenience store which sells food to be consumed off the premises as not a
covered “place of public accommodation” under Title II. Carrington v. Lawson’s Milk Co., 815
F.2d 702 (6th Cir. 1987) (per curium); Gigliotti v. Wawa, Inc., 2000 U.S. Dist. LEXIS 1021, at *4
(E.D. Pa. Feb. 4, 2000) (motion to dismiss granted where plaintiff failed to allege facts establishing
entity sold food for consumption on the premises or any other public accommodation); Fox v.
Vitamin Cottage Natural Grocers, No. 05cv00962REBPAC, 2006 U.S. Dist. LEXIS 101584, at
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**17-18 (D.C. Colo. June 22, 2006) (motion to dismiss appropriate because plaintiffs failed to
allege facts leading to conclude grocery store was a place of public accommodation under the
federal Civil Rights Act). Here, Johnson’s complaint lacks any allegations establishing that the
Boca Raton Publix store is a “place of public accommodation.” (See Exhibit 1). Johnson does not
allege food is made for consumption at this store. He does not allege whether there are areas where
one could consume food at the location. In fact, Johnson’s Complaint does not even allege that the
store is a “place of public accommodation” for Title II—it simply assumes it is the case.
Consequently, Johnson’s Title II and FCRA claims should be dismissed for this additional reason.
CONCLUSION
Defendant Publix Super Market, Inc. respectfully requests this Court enter an Order: (1)
dismissing the Verified Complaint of Plaintiff Boyd Johnson with prejudice for failure to state a
claim upon which relief can be granted; (2) granting Publix entitlement to its attorney’s fees under
42 U.S.C. § 2000a-3(b); and (3) granting such other and further relief as this Court deems just and
proper.
Dated: May 17, 2022. Respectfully submitted,
/s/ Jennifer Monrose Moore
Jennifer Monrose Moore, Esq.
Florida Bar Number 35602
OGLETREE, DEAKINS, NASH,
SMOAK & STEWART, P.C.
100 North Tampa Street, Suite 3600
Tampa, FL 33602
Telephone: 813.289.1247
Facsimile: 813.289.6530
jennifer.moore@ogletree.com
Attorneys for Defendant Publix Super Markets, Inc.
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51455411.v2-OGLETREE
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on May 17, 2022, the foregoing was filed with the Court using
the CM/ECF System. I FURTHER CERTIFY I served a true and correct copy of the foregoing
document by e-mail and U.S. mail to:
Boyd Johnson
Email: boyd5307@gmail.com
and in an abundance of caution at
634 NW 44th Terrace
Deerfield Beach, FL 33442
Plaintiff, Pro Se
/s/ Jennifer Monrose Moore
Attorney
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