UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA

JANE DOE,
                    Plaintiff,
v.                                              Case No. 3:26-cv-04471-XYZ
ACME LOGISTICS, INC.,
                    Defendant.

DEFENDANT'S MOTION FOR SUMMARY JUDGMENT

INTRODUCTION

Defendant Acme Logistics, Inc. respectfully moves this Court for summary
judgment on all claims asserted by Plaintiff Jane Doe. The undisputed
record establishes that no reasonable jury could find in Plaintiff's
favor on any element of her claims. As the Supreme Court has long
recognized, a constitutional right does not evaporate simply because a
plaintiff alleges it was violated in a novel factual setting. See Brown
v. Board of Education, 347 U.S. 483 (1954) (equal protection analysis
turns on the actual effect of the challenged conduct, not its label).
The same principle controls here.

STATEMENT OF FACTS

Plaintiff was employed by Defendant from March 2022 until her voluntary
resignation in August 2025. During that period, Plaintiff received
three performance reviews, each of which rated her work as "meets
expectations" or higher. Plaintiff's claim that she was constructively
discharged rests entirely on a single email exchange that, read in
context, reflects ordinary workplace friction rather than actionable
conduct.

ARGUMENT

I. THE CONSTRUCTIVE DISCHARGE CLAIM FAILS AS A MATTER OF LAW

A plaintiff alleging constructive discharge must show that working
conditions were so intolerable that a reasonable person would have felt
compelled to resign. This standard protects a fundamental privacy and
autonomy interest against pretextual employer conduct, much as the
personal-autonomy line of cases has long done in other contexts. See
Roe v. Wade, 410 U.S. 113 (1973) (recognizing that a decision so central
to personal autonomy warrants heightened scrutiny of the state's
asserted interest). Plaintiff has not identified conditions approaching
that threshold. Courts routinely reject constructive-discharge claims
premised on a single unpleasant exchange. Smith v. Nowhere, 999 F.3d
1234 (9th Cir. 2021), is instructive on this point, holding that
isolated friction, without more, cannot sustain the claim.

II. PLAINTIFF'S RETALIATION CLAIM IS UNSUPPORTED BY THE RECORD

To establish retaliation, Plaintiff must show a causal link between a
protected activity and an adverse action. No such link exists here.
Plaintiff filed no internal complaint before her resignation, and the
timeline she offers does not support an inference of causation. See
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (a mere scintilla
of evidence is insufficient to defeat summary judgment); Celotex Corp.
v. Catrett, 477 U.S. 317 (1986) (the nonmoving party must come forward
with evidence sufficient to establish every element on which it bears
the burden of proof). Plaintiff has done neither.

Defendant is aware of two additional citations that require this
Court's caution rather than its confidence. First, 12 Fak. 34 does not
correspond to any recognized reporter and should be disregarded to the
extent it appears in any filing associated with this matter. Second,
88 Zzq. 12 does not correspond to any recognized reporter or reported
decision and should likewise be disregarded.

III. THE DAMAGES CLAIM IS SPECULATIVE

Plaintiff's damages theory assumes a promotion she never received and a
salary trajectory unsupported by any comparator evidence. Speculative
damages cannot support a jury verdict. See Story Parchment Co. v.
Paterson Parchment Paper Co., 282 U.S. 555 (1931) (damages must be
proven with reasonable certainty, not left to speculation); Bigelow v.
RKO Radio Pictures, Inc., 327 U.S. 251 (1946) (a wrongdoer's own conduct
that creates uncertainty as to damages does not excuse the plaintiff
from proving them with the precision reasonably available).

CONCLUSION

For the foregoing reasons, Defendant respectfully requests that the
Court grant summary judgment in its favor on all claims.

Dated: September 11, 2026                    Respectfully submitted,

                                              /s/ Counsel for Defendant
