Equal Employment Opportunity Commission v. Midwest Farms, LLC

CourtDistrict Court, D. Colorado
DecidedMarch 18, 2025
Docket1:23-cv-02531
StatusUnknown

This text of Equal Employment Opportunity Commission v. Midwest Farms, LLC (Equal Employment Opportunity Commission v. Midwest Farms, LLC) is published on Counsel Stack Legal Research, covering District Court, D. Colorado primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Equal Employment Opportunity Commission v. Midwest Farms, LLC, (D. Colo. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Chief Judge Philip A. Brimmer

Civil Action No. 23-cv-02531-PAB-MDB

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,

Plaintiff,

v.

MIDWEST FARMS, LLC, and MIDWEST CAPITAL SERVICES, LLC,

Defendants. _____________________________________________________________________

ORDER _____________________________________________________________________

The matter before the Court is Plaintiff EEOC’s Motion to Strike Affirmative Defenses [Docket No. 56]. Defendants Midwest Farms, LLC and Midwest Capital Services, LLC filed a response, Docket No. 64, and plaintiff replied. Docket No. 65. The Court has jurisdiction pursuant to 28 U.S.C. § 1331. I. BACKGROUND On September 28, 2023, plaintiff, the Equal Employment Opportunity Commission (“EEOC”), filed suit in this case. Docket No. 1. On December 26, 2023, the EEOC amended its complaint. Docket No. 22. The EEOC amended its complaint again on January 30, 2024. Docket No. 35. In the second amended complaint, the EEOC brings claims for alleged sexual harassment on behalf of Andria Denny and a class of similarly situated female employees of defendant Midwest Farms, LLC who worked at the company’s farms located near Burlington, Colorado.1 Id. at 1–2, 6, 8, ¶¶ 36, 38, 58–59. The EEOC brings three claims against defendants under Title VII of the Civil Rights Act of 1964 (“Title VII”) and Title I of the Civil Rights Act of 1991 (“Title I”), namely, one claim of hostile work environment under 42 U.S.C. § 2000e-2(a)(1), one claim of constructive discharge under 42 U.S.C. § 2000e-2(a)(1), and one claim of

retaliation under 42 U.S.C. § 2000e-3(a). Id. at 9–13, ¶¶ 69–99. On February 27, 2024, defendants filed separate answers to the second amended complaint. Docket Nos. 49, 50. In its answer, Midwest Farms, LLC includes the following twenty-seven affirmative defenses: 1. Plaintiff’s Complaint, in whole or in part, fails to state a claim upon which relief may be granted against Defendant.

2. At all relevant times, Defendant acted in good faith without any intent to cause Ms. Denny or any of the members of the class of other alleged aggrieved individuals (“Class Members”) any harm.

3. Ms. Denny and the Class Members were at-will employees whose employment with Defendant could have been terminated at any time, for any reason, with or without notice.

4. Ms. Denny’s and the Class Members’ injuries, damages, or losses, if any, were proximately caused in whole or in part by their own acts or omissions, either in combination with one another or independent of one another.

5. Ms. Denny’s and the Class Members’ injuries, damages, or losses, if any, were proximately caused by the acts or omissions of third parties over whom Defendant possessed no ability to control or right of control.

6. Defendant’s actions were taken for legitimate nondiscriminatory and nonretaliatory reasons.

7. Defendant never took any adverse employment actions against Ms. Denny or any other Class Members.

1 The EEOC alleges that defendants Midwest Farms, LLC and Midwest Capital Services, LLC “comprise a single employer/integrated enterprise” for purposes of the EEOC’s claims. Docket No. 35 at 4, ¶ 22. 8. Ms. Denny and/or the Class Members cannot establish a causal connection between their individual statutory or common law rights and any adverse employment action.

9. Upon information and belief, Ms. Denny and/or the Class Members may have failed to mitigate their damages, if any, as required by law.

10. At all times pertinent herein, Defendant acted in accordance with all common law, statutory, regulatory, and policy obligations and without any intent to cause Ms. Denny or the Class Members any harm.

11. Ms. Denny’s and/or the Class Members’ injuries and damages, if any, were not aggravated by any action or omission of or by Defendant nor were they proximately caused by or related to any act or omission of Defendant.

12. Plaintiff’s, Ms. Denny’s, and the Class Members’ claims for damages are limited and/or subject to all applicable damages limitations and other similar provisions of both federal and Colorado law.

13. Plaintiff is not entitled to the relief sought in the Complaint under any of the theories asserted.

14. Some or all of Plaintiff’s claims are barred by the doctrine of laches.

15. Ms. Denny and some or all of the Class Members never engaged in any protected activity.

16. Ms. Denny and the Class Members were not subject to any conduct that was severe or pervasive as a matter of law.

17. Ms. Denny and the Class Members cannot establish an objectively hostile work environment as a matter of law.

18. Ms. Denny and the Class Members’ claims fail under the Faragher-Ellerth doctrine.

19. Defendant had effective policies and procedures for reporting complaints of harassment, discrimination, or retaliation, and Ms. Denny and the Class Members failed to avail themselves of these remedial avenues.

20. Defendant would have taken the same actions with respect to Ms. Denny’s employment and/or the Class Members’ employment in the absence of any alleged “protected activity.”

21. Plaintiff’s claims may be barred in whole or in part by the doctrines of consent, estoppel, waiver, or unclean hands. 22. Plaintiff may not seek relief on behalf of the Class Members beyond Ms. Denny and beyond the wrongdoing alleged in Ms. Denny’s Charge of Discrimination because Plaintiff did not discover such class members and other alleged unlawful acts during its underlying investigation.

23. Plaintiff did not satisfy its administrative prerequisites with respect to Defendant.

24. Plaintiff did not provide legally sufficient notice to Defendant of the scope of the allegations or claims against it during Plaintiff’s investigation.

25. Plaintiff failed in whole or in part to satisfy its statutory obligation to conciliate in good faith with Defendant before filing suit in violation of 42 U.S.C.[ ] § 2000e- 5(b).

26. Defendant and Midwest Capital do not [comprise] a single employer and/or an integrated enterprise.

27. Defendant specifically reserves the right to amend its Answer to include additional defenses and affirmative defenses and/or delete defenses and affirmative defenses which have become applicable or non-applicable upon completion of additional discovery.

Docket No. 49 at 14–17, ¶¶ 1–27. Midwest Capital Services, LLC, includes the same twenty-seven affirmative defenses in its answer, but in a different order. See Docket No. 50 at 11–13, ¶¶ 1–27. On March 19, 2024, the EEOC filed its motion to strike defendants’ affirmative defenses pursuant to Federal Rule of Civil Procedure 12(f). Docket No. 56. The EEOC seeks to strike all of defendants’ affirmative defenses except defenses two, nine, fourteen, and eighteen.2 Id. at 1. On April 23, 2024, defendants responded, Docket No. 64, and the EEOC replied on May 7, 2024. Docket No. 65.

2 The Court will follow the parties’ convention of referring to each affirmative defense by the number assigned to the defense in Midwest Farm, LLC’s answer. See Docket No. 56 at 1; Docket No. 64 at 4 n.2. II.

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Equal Employment Opportunity Commission v. Midwest Farms, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/equal-employment-opportunity-commission-v-midwest-farms-llc-cod-2025.