Rachel A. Royer filed a civil action in the United States District Court for the Eastern District of North Carolina against Syneos Health, LLC. Royer alleged that the defendant failed to accommodate her religious beliefs in violation of Title VII of the Civil Rights Act of 1964. She also raised federal constitutional claims and state law claims for fraud and punitive damages. The district court granted the defendant's motion to dismiss the case. Royer appealed, challenging the dismissal of her Title VII claim and the other claims raised in her complaint.
The Fourth Circuit reviewed the district court's order granting the motion to dismiss. Regarding the Title VII claim, the court applied the standard from Rouse v. Lee, which requires a plaintiff to establish extraordinary circumstances beyond their control to excuse a failure to comply with the 90-day statutory time limit for administrative exhaustion. The appellate court found that Royer failed to provide evidence that such extraordinary circumstances prevented her from meeting the deadline. Consequently, the court determined the district court correctly dismissed the Title VII claim. Regarding the remaining claims, the court addressed the fraud claim by citing Xia Bi v. McAuliffe, noting that reasonable, detrimental reliance upon a misrepresentation is an essential element of fraud that must be pleaded with particularity. The court found the pleading insufficient. Finally, regarding punitive damages, the court cited Sykes v. Health Network Sols., Inc., observing that North Carolina has no freestanding claim for punitive damages. Based on these determinations, the court found no reversible error in the district court's judgment.
The judgment of the district court dismissing the case is final. Royer is left without relief on the grounds of religious accommodation, fraud, or punitive damages. The decision reinforces the strict application of the 90-day exhaustion deadline in the Fourth Circuit and clarifies the pleading requirements for fraud and the unavailability of standalone punitive damages claims in North Carolina state law contexts within this circuit.