Allen v. Jacksonville University

CourtDistrict Court, M.D. Florida
DecidedMarch 29, 2022
Docket3:21-cv-00178
StatusUnknown

This text of Allen v. Jacksonville University (Allen v. Jacksonville University) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Allen v. Jacksonville University, (M.D. Fla. 2022).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA JACKSONVILLE DIVISION

ASHLEY ALLEN, individually and on behalf of all others similarly situated,

Plaintiff,

v. Case No. 3:21-cv-178-MMH-LLL

JACKSONVILLE UNIVERSITY,

Defendant.

ORDER THIS CAUSE is before the Court on Defendant Jacksonville University’s (JU) Motion to Stay the Case Pending Resolution of Dispositive Motion. (Doc. 12; Motion to Stay). Plaintiff Ashley Allen filed a Response in Opposition on May 27, 2021. (Doc. 18; Allen’s Response in Opposition). Accordingly, this matter is ripe for review. BACKGROUND In early 2020, the COVID-19 pandemic upended daily life. As infection rates climbed, JU—a private university—moved classes online, closed campus facilities, and encouraged students to leave their residence halls. See Corrected Class Action Complaint (Doc. 6; Complaint) ¶¶ 23, 28–31. Plaintiff Ashley Allen was a JU student at the time. Id. ¶ 1. Allen subsequently sued JU on behalf of all students who paid tuition and fees for the spring 2020 semester. Id. According to Allen, JU’s response to COVID-19 violated various contracts that existed between the school and the students.

Id. ¶¶ 94, 128, 147, 150. She also alleges that JU was unjustly enriched when it retained the students’ tuition and fee payments. Id. ¶¶ 103, 134, 155. Finally, Allen contends that JU violated Florida’s Deceptive and Unfair Trade Practices

Act. Id. ¶ 167. JU moved to dismiss Allen’s Amended Complaint on May 14, 2021. (Doc. 11; Motion to Dismiss). On the same day, JU moved to stay the case pending resolution of the Motion. (Doc. 12; Motion to Stay). JU asserts that a stay is

warranted because the claims will likely be dismissed, and a stay will prevent costly discovery. Id. at 5–6, 11, 14. Allen counters that the routine burdens of discovery do not justify a stay. See Allen’s Response in Opposition at 3. She also argues that a stay would prejudice both her and the putative class by

delaying relief. Id. at 7. JU also asked the Court to defer ruling on the Motion to Dismiss until HB 1261—a bill granting broad immunity to educational institutions—was presented to the Governor and signed into law. See Motion to Stay at 11. JU

argued that the stay was necessary so the parties could fully brief the law in connection with this case. Id. HB 1261 was signed into law on June 29, 2021, and both parties have fully briefed the issue. (Doc. 36; JU’s Supplemental Brief); (Doc. 38; Allen’s Supplemental Brief). In Allen’s Supplemental Brief, she challenges the constitutionality of Florida Statute section 768.39.

Specifically, Allen argues that section 768.39 violates the Contracts Clause and the Due Process Clause of the United States Constitution, and the Contracts Clause and right of access to courts in the Florida Constitution. See Allen’s Supplemental Brief at 1–11, 14–17.1

DISCUSSION District courts are vested with broad discretion to stay proceedings. Gibson v. Comm'r of Soc. Sec., No. 6:21-cv-810-GKS-LRH, 2021 WL 5926348,

at *1 (M.D. Fla. July 14, 2021) (staying entire case because of a backlog caused by COVID-19); Murdock v. Santander Consumer USA Inc., No. 2:15-cv-268- SPC-CM, 2016 WL 3913135, at *2 (M.D. Fla. July 20, 2016) (finding that “a stay of the entire case will promote judicial economy and efficiency”). Pursuant

to their authority, district courts may stay proceedings as a means of managing their dockets. Lewis v. Abbott Labs., Inc., No. 6:19-cv-909-GAP-LHP, 2019 WL 5448289, at *2 (M.D. Fla. Aug. 2, 2019); see also Dietz v. Bouldin, 579 U.S. 40,

1 The constitutional issue is also discussed in JU’s Supplemental Brief (Doc. 36) and JU’s Reply to Allen’s Supplemental Brief. (Doc. 43). 47 (2016) (“[D]istrict courts have the inherent authority to manage their dockets and courtrooms with a view toward the efficient and expedient resolution of cases.”). Additionally, in appropriate circumstances, courts may enter a stay to promote judicial economy, reduce confusion and prejudice, and

prevent possibly inconsistent resolutions. Terec v. Reg’l Acceptance Corp., No. 8:16-cv-2615-JSM-MAP, 2017 WL 662181, at *1 (M.D. Fla. Feb. 17, 2017) (citing Rodriguez v. DFS Servs., LLC, No. 8:15–cv–2601-JSM-TBM, 2016 WL

369052, at *2 (M.D. Fla. Feb. 1, 2016)). So long as the scope of a stay is limited and a reasonable justification is provided, courts do not abuse their discretion by granting a stay. Trujillo v. Conover & Co. Commc’ns, Inc., 221 F.3d 1262, 1264 (11th Cir. 2000).

Here, the Court need not address the arguments presented by the parties in favor and in opposition of a stay because the Court finds that the procedural posture of the case warrants a stay. Notably, Rule 5.1(a) of the Federal Rules of Civil Procedure, requires a party “drawing into question the

constitutionality of a … state statute” to “promptly” file a notice of the constitutional question and identify the paper that raises the question. Fed. R. Civ. P. 5.1(a)(1)(B). The party must then serve the notice on the state attorney general. Fed. R. Civ. P. 5.1(a)(2). The court is also obligated to certify the constitutional question to the state attorney general. Fed. R. Civ. P. 5.1(b).2 After the notice is filed or certification is made, whichever is earlier, the attorney general has sixty days to intervene and present “argument[s] on the question of constitutionality.” Fed. R. Civ. P. 5.1(c); 28 U.S.C. § 2403(b). During

the sixty-day period, the court “may not enter a final judgment holding the statute unconstitutional.” Fed. R. Civ. P. 5.1(c). In the months following the filing of Allen’s Supplemental Brief in which

she challenges the constitutionality of Florida Statute section 768.39, Allen failed to file a notice of the constitutional question with the Court, as required by Rule 5.1(a)(1). She also failed to give notice to Florida’s Attorney General as required by Rule 5.1(a)(2). As a consequence of Allen’s failure to comply with

her obligations under Rule 5.1(a), the Court’s obligation under Rule 5.1(b) remains outstanding. On March 22, 2022, the Court brought this issue to the parties’ attention. (Doc. 51). According to Allen, one day later, she provided the Attorney General notice pursuant to Rule 5.1(a)(2).3 (Doc. 54; Plaintiff’s Notice

of Rule 5.1(a) Requirements). And by this Order, the Court discharges its notice

2 Pursuant to 28 U.S.C. § 2403(b), if the constitutionality of a state statute is challenged in an action to which the state is not a party, the Court “shall certify such fact to the attorney general of the State” and permit the attorney general an opportunity to intervene.

3 Allen still has not actually complied with Rule 5.1(a). Nor did she make any effort to explain the reason for her failure to satisfy the requirements of Rule 5.1 in a timely manner.

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Related

Dietz v. Bouldin
579 U.S. 40 (Supreme Court, 2016)

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