John Houhoulas v. California Department of Transportation Human Resources, et al.
May 4, 2026·2:22-cv-00413-TLN-DB·Unpublished·By Aisha Johnson
The Ninth Circuit affirmed the dismissal of an employment discrimination appeal filed pro se by John Houhoulas. The court held that individual employees cannot be sued under Title VII and that state law claims were barred by the California Government Claims Act.
Plaintiff John Houhoulas appealed a district court judgment dismissing his employment action alleging federal and state law claims. He filed the appeal pro se.
The court’s reasoning
The court reviewed the dismissal de novo under Federal Rule of Civil Procedure twelve comma six. It affirmed the dismissal of Title VII discrimination claims because individual defendants were sued in their personal capacities, and individual employees are not employers under Title VII. The court also affirmed the dismissal of state law claims because the complaint alleged the defendants acted within the scope of public employment, and the plaintiff failed to allege compliance with the California Government Claims Act.
What it means going forward
The decision reinforces that private individuals cannot be held liable under Title VII for employment discrimination and requires strict adherence to state notice-of-claim procedures for suits against public employees.
