Labor & Employment Law Daily Wrap Up, DISCRIMINATION—D. Md.: African-American dance instructor cannot proceed with discrimination, retaliation claims against small studios, (Oct 17, 2025)

By Jason Albright, J.D.

She alleged that her manager at Arthur Murray Dance Studio Baltimore referred to her movements “as similar to hanging (from a tree) during a lynching.”

An African-American dance instructor with dyslexia, fired from a dance studio in Columbia, Maryland after her manager allegedly called her “stupid,” and then fired from a related studio in Baltimore after her manager there—who allegedly brought her fried chicken and indicated that he did so because of her race—purportedly became angry that she filed a workers’ compensation claim, cannot proceed with her federal discrimination or retaliation claims against the small studios or with any claims against their corporate parent. She could not establish that she was an employee of the corporate parent, and she did not allege that either studio employed a sufficient number of employees to qualify as an employer for purposes of her discrimination or retaliation claims (Sharp v. Arthur Murray International Inc., No. 24-cv-2605-ABA (D. Md. Oct. 16, 2025)).

Dance trainer. The plaintiff, who began her employment as a dance trainer at Arthur Murray Dance Studio (AMDS) of Columbia on May 9, 2023, alleged that she was initially instructed by management that her hiring was contingent upon her having a babysitter for her children. This, she alleged, was discriminatory heightened scrutiny, which caused her extreme distress.

Alleged comments about race. She also alleged that another “employee told her that she should not call herself an African American because they do not know who they are.” She was then allegedly subjected to racial comments and slurs from the manager of AMDS of Columbia, including alleged statements about her course hair and direction to “get back on the boat.”

Dyslexia. The trainer, who is dyslexic, also and alleged that, when she requested a reasonable accommodation for her dyslexia, her manager called her “stupid.

Fired. Then, on May 26, 2023, an hour after complaining to the manager about the alleged disparate treatment, racially charged bullying, and condescending and humiliating comments, she was fired. She alleged that she is aware of two other African-American employees who were allegedly fired for discriminatory reasons.

Baltimore manager and fried chicken, lynching comments. She further alleged that she was subsequently transferred to AMDS Baltimore, however. And there, her manager allegedly brought her fried chicken and indicated that he did so because of her race. On another occasion, she alleged, during her performance of a dance routine, the Baltimore manager allegedly referred to her movements “as similar to hanging (from a tree) during a lynching.”

Injury and final termination. During a dance routine training, she was injured by a student and required urgent hospitalization. She then filed a workers’ compensation claim, but the Baltimore manager and his wife, a co-manager of AMDS Baltimore, were allegedly furious when they were notified, and she was then terminated “following” the filing of that claim, on June 15, 2023.

Arthur Murray International Inc. The employee mentioned Arthur Murray International Inc. (AMII) only twice in her factual assertions, according to the court, and then broadly stated in the “Parties” section of her amended complaint that “at all relevant times, [AMII] employed the Plaintiff.”

Lawsuit. In her suit she asserted five claims: (1) race discrimination under the Maryland Fair Employment Practices Act (MFEPA) and Title VII; (2) disability discrimination under the ADA, MFEPA, and Title VII; (3) a hostile work environment (HWE) under MFEPA; (4) retaliation under MFEPA and Title VII; and (5) wrongful termination in violation of public policy, only against AMII.

All three defendants moved to dismiss, and AMDS Baltimore and AMII also, in the alternative, moved for summary judgment.

Not an employee of AMII. The court first found that the instructor failed to establish that she was an employee of AMII. Her mere naming of the three defendants as “‘Arthur Murray’ Defendants” and broadly stating that AMII employed her at all relevant times were bare “labels and conclusion,” according to the court. Without more, it could not assume that they were true. To the extent that she argued that her “transfer[]” from AMDS of Columbia to AMDS Baltimore indicated employment decisions made by AMII, she also did not plead any facts regarding what entity coordinated the transfer or how she could have been transferred after alleging that she was fired.

Finally, she did not allege that AMII was involved in her hiring or training with either franchisee studio, that AMII was aware of her workers’ compensation claim and instructed AMDS Baltimore to terminate her employment, that AMII was in possession of her employment records from the franchisee studios, or any other allegation that would establish that AMII exerted sufficient control over the franchisee studios to constitute a joint employer. The court thus dismissed all claims against AMII without prejudice.

AMDS of Columbia. Nor did she sufficiently allege that AMDS of Columbia constituted an employer for the purposes of her discrimination and retaliation claims under Title VII, the ADA, and the MFEPA, all of which define “employer” as a person or business that employs 15 or more employees for each working day in each of 20 or more calendar weeks in the current or preceding calendar year. Based on the facts alleged, the employee at most alleged that AMDS of Columbia employed four or five employees: the plaintiff, a manager, another unnamed employee, and two other named employees. The discrimination and retaliation claims were accordingly dismissed without prejudice.

AMDS Baltimore. This was also the case with respect to her discrimination and retaliation claims against AMDS Baltimore. Payroll records provided by ADP, the payroll company for AMDS Baltimore, clearly showed that, from as early as December 25, 2021 (approximately 75 weeks before the start of her employment with AMDS Baltimore) through as late as December 29, 2023 (approximate 28 weeks after the termination of her employment with AMDS Baltimore), AMDS Baltimore did not employ more than six employees during any pay period. The court accordingly granted AMDS Baltimore’s motion for summary judgment as to the discrimination and retaliation claims.

No fees for AMII. Despite dismissal of her claims against AMII, the court declined to award that entity attorney fees. The court simply did not find that she pursued the claims against AMII in bad faith or that her counsel “multiplie[d] the proceedings in [the] case unreasonably and vexatiously.” 28 U.S.C. § 1927.

Count 3. Finally, the court reserved ruling on AMDS Baltimore’s motion to dismiss Count 3, the HWE claim under the MFEPA, pending the plaintiff’s decision whether to move to amend her complaint. Absent an amended complaint stating federal claims on which relief can be granted, the court said, it expects to decline to exercise supplemental jurisdiction over the HWE claim.

The case is No. 24-cv-2605-ABA.

Judge: Abelson, A.

Attorneys: Andrew Nyombi (KNA Pearl Law) for Mykia Sharp. A Emmett F McGee, Jr. (Jackson Lewis) for Arthur Murray International Inc. Michael John Neary (Lerch Early and Brewer) for Arthur Murray Dance Studio of Columbia. Andrew Marc Dansicker (Law Offices of Andrew M. Dansicker) for Arthur Murray Dance Studio of Baltimore.

Companies: Arthur Murray International Inc.; Arthur Murray Dance Studio of Columbia; Arthur Murray Dance Studio of Baltimore

Cases: RaceDiscrimination DisabilityDiscrimination Discrimination Retaliation Discharge CoverageLiability EmployeeStatus Procedure AttorneysFees MarylandNews