Bazemore v. International Longshoremen's Association, ILA Local 1475

District Court, S.D. Georgia·Decided August 22, 2024·No. 4:23-cv-00372·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORGIA SAVANNAH DIVISION

SHANNON BAZEMORE,

Plaintiffs, CIVIL ACTION NO.: 4:23-cv-372

v.

INTERNATIONAL LONGSHOREMEN’S ASSOCIATION LOCAL 1475 CLERKS AND CHECKERS UNION, INC.,

Defendant.

O RDE R

Pro se Plaintiff Shannon Bazemore sued Defendant International Longshoreman’s Association Local 1475 Clerks and Checkers Union, Inc.’s (“Local 1475”) under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e, et seq. (“Title VII”), and under Title I of the Civil Rights Act of 1991, which is codified at 42 U.S.C. § 1981a,1 alleging that she was discriminated against because of her race. (Doc. 1.) Presently before the Court is Local 1475’s Motion to Dismiss, (doc. 12), and Request for Judicial Notice in Support of its Motion to Dismiss, (doc. 14). Local 1475 moves to dismiss the Complaint, arguing that Bazemore failed to exhaust her administrative remedies before filing suit and that she has failed to plead facts to support a claim of racial discrimination under Title VII. (Doc. 13.) For the reasons discussed below, the Court

1 Title I of the Civil Rights Act of 1991 is codified at 42 U.S.C. § 1981a. Section § 1981a broadened the remedies available to successful Title VII litigants. See 42 U.S.C. § 1981a, 2000e-5(g). It does not provide an independent cause of action. Riles v. Augusta-Richmond Cnty. Comm’n, No. CV 116-214, 2017 WL 3597488, at *2 (S.D. Ga. Aug. 21, 2017). GRANTS Local 1475’s Request for Judicial Notice as unopposed, (doc. 14), and GRANTS Local 1475’s Motion to Dismiss, (doc. 12). BACKGROUND I. Bazemore’s Employment with Local 1475 and Seniority Status

Local 1475 is a local labor organization that serves as the bargaining representative for clerks and checkers in the Port of Savannah. (Doc. 1, p. 3.) Local 1475 employs/represents at least 150 bargaining unit members and is party to a collective bargaining agreement (“CBA”) with the Georgia Stevedore Association. (Id. at p. 4.) Bazemore, an African-American woman, works as a clerk and checker and is a bargaining unit member represented by Local 1475. (Id. at pp. 3, 5.) Local 1475 operates a hiring hall where it assigns work to clerks and checkers in accordance with the order set forth in the CBA, referred to as the Savannah Clerks and Checkers Seniority Plan (“Seniority Plan”). (Doc. 1, p. 3; doc 14-1.)2 Under the Seniority Plan, clerks and checkers are divided into “Classes.” (See doc. 14-1.) Each Class consists of clerks and checkers

who achieved at least 700 hours of work in a specific “contract year” and maintained 700 hours of work in each contract year thereafter. (Id. at p. 2.) Under the Seniority Plan, contract years begin on October 1 and end on September 30, and are designated by the calendar years they straddle (e.g., 2023–24). (Id. at p. 4.) Before medical benefits, a pension plan, or seniority status can be acquired, a member must accumulate and maintain at least 700 work hours during a calendar year. (Doc. 1, p. 6.)

2 For the reasons discussed in Discussion Section I, infra, the Court has taken judicial notice of certain undisputed facts even though they were not included in the Complaint. Bazemore was hired by Local 1475 to work as a clerk and checker in September 2020, as part of an “emergency street list” (the “Emergency List”). (Id.) During the 2020–21 contract year, Bazemore obtained at least 700 hours worked. (Id.) Bazemore’s seniority classification was “ZZZ” because of her presence on the Emergency List. (Id.) Class ZZZ contained 112 members:

22 African American workers and 90 white workers. (Id. at p. 9.) Bazemore received communication from Local 1475 that, although she “performed the same job functions, worked through the pandemic, and accumulated 700 work hours during the contract year 2020–21,” she did not obtain “AA” seniority because she was hired from the Emergency List. (Id. at p. 6.) In September 2021, Local 1475 required members on the Emergency List to sign a waiver of seniority rights, which stated that “[a]ny hours worked before the creation of any future list(s) being established will not qualify as credited hours toward seniority under the CBA.” (Id. at pp. 10–11; doc. 14-4. p. 2.) Bazemore herself did not sign this waiver and another member of the Emergency List signed it for her. (Doc. 1, p. 10 n.4.) Local 1475 entered into a Memorandum of understanding on October 1, 2021 (“2021

MOU”) to supplement the Seniority List. (Doc. 14-2.) Under the 2021 MOU, all workers on the Emergency List who earned 700 hours in the 2020–21 contract year were put on “Extra List 5,” effective October 1, 2021, which would put them in Class HH. (Id. at p. 5.) Workers who were on Extra Lists 1, 2, 3, or 4 (and thus not on the Emergency List) who worked 700 hours in the 2020–21 contract year were eligible for Class AA seniority status.3 (Id. at pp. 2–3.) The 2021 MOU did not mention race. (See generally id.)

3 Bazemore also alleges that, “in the eleventh hour[,]” Local 1475 “disadvantageously revise[d] the MOU.” (Doc. 1, pp. 9–10.) The Complaint does not clarify what was revised or how Bazemore would have been classified before the alleged revision. (Id.) Before the end of contract year 2021–22, a white bargaining member, Jimmy Gunby, sent out a group text to other white bargaining members. (Doc. 1, p. 8.) The body of the text read in relevant part: “[H]ello everyone this is Jimmy Gunby[.] This text is for information only please don’t respond to this group text. [Extra] List 5 will not go into effect until October 1st, which means all the ZZZ’s that make their hours will be in our category . . . . The total for our category is sitting at 26 without counting the ZZZ’s that will make it. By my estimation we are looking at 15–20 of them making it if we don’t block them a little better than we have been. . . . If you can please pick up at least 20 to 30 hours (2–3) shifts a week or more if you can. This will make a big difference for us next year if we can limit how many get in with us. Once again I did not send this for everyone to respond I’m just giving the information that I know and asking if you can block a few shifts a week it will make the difference in maybe 5–10 of the ZZZ’s not making it.” (Id.) Bazemore later lodged a racial discrimination grievance against Local 1475 and emailed it to various Local 1475 officials. (Id. at p. 7.) In response to the grievance, Bazemore was made to participate in a video teleconference on March 3, 2022. (Id.) During the teleconference, it was communicated to Bazemore that, although she would not receive AA seniority, those who worked on the Emergency List would be awarded HH seniority rights “sometime in the near future” to recognize the work they performed during the pandemic. (Id.) Bazemore received HH seniority status at the end of the 2021–22 contract year. (Id. at p. 13.) On June 1, 2023, Local 1475 enacted an Addendum to the 2021 MOI (“2023 Addendum”). (Doc. 14-3.) The 2023 Addendum subdivided Class HH into two Subclasses designated as HH-1 and HH-2. (Id. at p. 3.) The 2023 MOU defined Subclass HH-1 as All individuals who worked at least 700 hours through the Local 1475 hiring system during both the 2020–21 and 2021–22 Contract Years, and all individuals who were on an [E]mergency [L]ist during the 2020–21 Contract Year and worked at least 700 hours through the Local 1475 hiring system during the 2021–22 Contract Year.

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