Davis v. Mar-Jac Poultry AL, LLC

District Court, N.D. Alabama·Decided September 6, 2024·No. 6:18-cv-01433·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA JASPER DIVISION

CURTIS DAVIS, ) ) Plaintiff, ) ) DERELL D. HARRIS, ) )

Intervenor Plaintiff, )

)

SHANE HUMPHRIES, ) ) Intervenor Plaintiff, ) ) DEREK JOHNSON, )

Intervenor Plaintiff, ) ) TABITHA SMITH, ) ) Intervenor Plaintiff, )

HEATHER LENTZ, )

WILLIAM SHANKLIN, )

THOMAS GARNER, )

) EDDIE M. BROWN, ) ) Intervenor Plaintiff, ) Case No. 6:18-cv-01433-LSC ) v. ) ) MAR-JAC POULTRY AL, LLC, ) ) Defendants. )

MEMORANDUM OF OPINION I. INTRODUCTION Before the Court is Derell D. Harris, Shane Humphries, Derek Johnson, Tabitha Smith, Heather Lentz, William Shanklin, Thomas Garner, and Eddie M. Brown’s (“Intervenors”) Motion to Intervene. (Doc. 203.) In the Motion, Intervenors ask to either intervene as of right under Rule 24(a)(2) or, in the alternative, to intervene under Rule 24(b)(1). (Id. at 1, 10.) Fed. R. Civ. P. 24(a)(2), 24(b)(1). By intervening they intend to either appeal the Court’s denial of class certification under Rule 23(b)(3) and “serve as additional or supplemental class representatives of the class certified under Rule 23(b)(2)” or, in the alternative, to pursue their individual claims “on an individual, non-class basis.” (Id. at 1.) Fed. R. Civ. P. 23(b). For the reasons stated below, the Motion to Intervene under Rule 24(a)(2) is due to be DENIED and the Motion to Intervene under Rule 24(b)(1) is due to be GRANTED IN PART and DENIED IN PART. 2 II. BACKGROUND This case was filed by Curtis Davis, an African-American male, on September

4, 2018. (Doc. 1.) Davis asserted three causes of action based on his unsuccessful application for employment at Mar-Jac’s poultry-processing plant in January 2018: Count I: Title VII – Disparate Impact; Count II: Title VII and § 1981 – Intentional

Disparate Treatment; and Count III: Title VII – Punitive Damages. (Doc. 29.) He further sought to represent a putative class of non-Hispanic applicants whose applications were likewise rejected by Mar-Jac under both Rule 23(b)(2), for injunctive and declaratory relief, and Rule 23(b)(3), for monetary damages.

On March 30, 2021, the Court denied certification of either type of class. (Doc. 122.) The Court determined that all the requirements of Rule 23(a) were

satisfied. (Id. at 28.) However, regarding the Rule 23(b)(3) class, the Court found that individual issues predominated issues common to the class for both the disparate treatment and disparate impact claims. (Id. at 32.) For the Rule 23(b)(2) class, the

Court denied certification because Davis had not shown how injunctive or declaratory remedies would provide relief to the entire class. (Id. at 34.)

On August 5, 2021, the Court reconsidered class certification. (Doc. 131.) In that Opinion, the Court determined that certification under Rule 23(b)(3) remained inappropriate because individual issues predominated. (Id. at 6.) But the Court found 3 that an injunctive and declaratory relief class was due to be certified under Rule 23(b)(2). (Id.) Therefore, the Court certified the following Rule 23(b)(2) class:

All persons not of Hispanic race and or origin seeking employment on or after February 22, 2016 in unskilled positions on the production floor of Mar-Jac’s Jasper Plant, and not hired within 45- days after seeking such employment. (Id.) The Court again reconsidered on January 19, 2024, but once again the Court denied class certification under Rule 23(b)(3). (Doc. 183.) On August 8, 2024, the Court approved the parties’ agreed upon settlement

and entered judgment on the class claims in accordance with the parties’ stipulation. (Doc. 202.) On September 3, 2024, the Intervenors filed this Motion to Intervene. (Doc. 203.)

III. DISCUSSION

A. Rule 24(a) intervention as of right A party has a “right” to intervene, under Rule 24(a), if he “establish[es] that

‘(1) his application to intervene is timely; (2) he has an interest relating to the property or transaction which is the subject of the action; (3) he is so situated that disposition of the action, as a practical matter, may impede or impair his ability to

protect that interest; and (4) his interest is represented inadequately by the existing 4 parties to the suit.’” Fox v. Tyson Foods, Inc., 519 F.3d 1298, 1302-03 (11th Cir. 2008) (quoting Chiles v. Thornburgh, 865 F.2d 1197, 1213 (11th Cir. 1989)); Fed.

R. Civ. P. 24(a). In short, Rule 24(a)(2) intervention as a right requires showing: timeliness, “adequate interest, a possible impairment of that interest and lack of adequate representation of that interest by existing parties.” Dimond v. District of

Columbia, 792 F.2d 179, 192 (D.C. Cir. 1986). First, timeliness. When the purpose of intervening is to appeal a court’s denial of class certification, the intervention is timely when brought within the deadline to appeal the court’s final judgment in the case. United Airlines, Inc. v. McDonald, 432

U.S. 385, 396 (1977) (finding intervention timely because it was “within the time period in which the named plaintiffs could have taken an appeal” and did not seek to assert individual claims). Next, a party’s interest in the subject matter of the

litigation must be “direct, substantial and legally protectable.” Georgia v. U.S. Army Corps of Eng’rs, 302 F.3d 1242, 1249 (11th Cir. 2002). And the party’s ability to protect their interest must be impaired absent intervention. See Stone v. First Union Corp., 371 F.3d 1305, 1310 (11th Cir. 2004) (finding the interest of intervenors

seeking to intervene in named plaintiff’s individual suit would be sufficiently impaired by negative stare decisis effect for the named plaintiff’s case because “one court’s ruling on whether the bank’s policy, as a matter of law, was in violation of

the ADEA could influence later suits.”) Finally, in the context of Rule 24(a) 5 intervention, courts “presume adequate representation when an existing party seeks the same objectives as the would-be interveners. But the presumption is weak” and

can be overcome with any evidence to the contrary. Clark v. Putnam Cnty., 168 F.3d 458 (11th Cir. 1999) (internal citations omitted). See also Stone v. First Union Corp., 371 F.3d 1305, 1312 (finding the presumption of adequate representation was

overcome when the court had denied class certification because the named plaintiff was “not an adequate representative plaintiff for class action purposes because the plaintiffs do not have sufficiently similar claims against the bank.”). In their Motion, Intervenors heavily rely on United Airlines, arguing they

“stand in the same post-judgment posture as the putative class members in United Airlines, who were held to have the right to intervene to appeal the denial of class certification after entry of a final judgment making that adverse determination

appealable.” (Doc.

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Davis v. Mar-Jac Poultry AL, LLC, (N.D. Ala. 2024).

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