Glanton v. Wayne Farms LLC

CourtDistrict Court, M.D. Alabama
DecidedAugust 23, 2019
Docket1:19-cv-00327
StatusUnknown

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

Bluebook
Glanton v. Wayne Farms LLC, (M.D. Ala. 2019).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA SOUTHERN DIVISION

ZACORIUS GLANTON, ) ) Plaintiff, ) ) v. ) CIV. ACT. NO. 1:19-cv-327-ECM ) (WO) WAYNE FARMS, LLC, ) ) Defendant. )

MEMORANDUM OPINION and ORDER

Now pending before the Court are a motion to dismiss filed by Defendant Wayne Farms, LLC (“Wayne Farms”) (Doc. 10) on June 14, 2019, and a motion to amend filed by Plaintiff Zacorius Glanton (“Glanton”) (Doc. 16) on July 15, 2019. On May 7, 2019 Glanton filed a complaint against Wayne Farms, bringing a hostile work environment claim pursuant to Title VII of the Civil Rights Act of 1964 (count one), a claim of constructive discharge pursuant to Title VII (count two), a state-law claim of outrageous conduct (count three), a state-law claim of invasion of privacy (count four), a state-law battery claim (count five), and a state-law negligent supervision claim (count six) (Doc. 1). After Wayne Farms moved to dismiss the complaint, Glanton moved to file an amended complaint, attaching a proposed amended complaint, and stating that the amendment would cure deficiencies identified by Wayne Farms. (Doc. 16 & 16-1). Upon consideration of the complaint, the proposed amended complaint, and the briefs of the parties, and for the reasons that follow, the motion to amend is due to be GRANTED to the extent that Glanton will be allowed the opportunity to file an amended complaint. I. FACTS

The allegations of the complaint are as follows: Glanton was an employee of Wayne Farms from March 1 to July 18, 2018. Glanton’s employment was constructively terminated on July 18, 2018. Glanton identifies another employee of Wayne Farms, Allen Stephenson (“Stephenson”), as a person who sexually harassed him. Glanton complained about

unwanted touching to his supervisor who at first laughed off the behavior, and then agreed to move Glanton to another line. Glanton alleges that management observed Glanton and Stephenson later that same day, and that Glanton then went to the office and reported Stephenson’s conduct. (Doc. 1, at p. 3-4). Glanton acknowledges that management moved him after his complaint, but states

that Stephenson did not stop his inappropriate behavior. According to Glanton, Stephenson touched him inappropriately on a weekly basis. On June 29, 2018, after Stephenson threatened to physically fight Glanton, members of management took Glanton to human resources where he again complained. Glanton alleges that Stephenson was still trying to get his attention after the meeting with human resources, so Glanton left the floor and has

not returned to Wayne Farms. (Doc. 1, at p. 5-7). II. LEGAL STANDARDS A. Motion to Dismiss A Rule 12(b)(6) motion to dismiss tests the sufficiency of the complaint against the

legal standard set forth in Rule 8: “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). “To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U. S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U. S. 544, 570 (2007)).

“Determining whether a complaint states a plausible claim for relief [is] ... a context- specific task that requires the reviewing court to draw on its judicial experience and common sense.” Id. at 663 (alteration in original) (citation omitted). The plausibility standard requires “more than a sheer possibility that a defendant has acted unlawfully.” Iqbal, 556 U. S. at 678. Conclusory allegations that are merely “conceivable” and fail to

rise “above the speculative level” are insufficient to meet the plausibility standard. Twombly, 550 U. S. at 555, 570. This pleading standard “does not require ‘detailed factual allegations,’ but it demands more than an unadorned, the-defendant-unlawfully-harmed- me accusation.” Id. at 678. Indeed, “[a] pleading that offers ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action will not do.’” Id.

B. Motion to Amend Generally, leave to amend should be “freely given when justice so requires.” Fed. R. Civ. P. 15(a). Rule 15(a) does not require an amendment where “there has been undue delay in filing, bad faith or dilatory motives, prejudice to the opposing parties,” or where the amendment would be futile. Local 472 of United Ass'n of Journeymen & Apprentices of Plumbing & Pipefitting v. Ga. Power Co., 684 F.2d 721, 724 (11th Cir.1982).

III. DISCUSSION Wayne Farms moves to dismiss all of the counts of Glanton’s complaint and opposes amendment of the complaint on the ground of futility. Initially, Wayne Farms moved to dismiss the hostile environment claim on the ground that Glanton has not alleged

that action was taken against him on the basis of his gender. In response, Glanton has proposed an amendment to the complaint to make it clear that the actions he has identified were taken against him on the basis of his gender. (Doc. 16-1, at p. 3). Wayne Farms concedes that this aspect of the proposed amended complaint “would arguably cure” a pleading deficiency. (Doc. 18, at p. 2).

Wayne Farms does not, however, concede that the proposed amendment cures all of the pleading deficiencies identified in the motion to dismiss. In fact, Wayne Farms argues that the federal hostile environment and state-law outrageous conduct, invasion of privacy, and battery claims are all due to be dismissed and any amendment is futile because Glanton has not alleged a basis for holding the employer, Wayne Farms, liable for the

actions of Stephenson, a co-worker of Glanton. Wayne Farms also contends that the allegations of Glanton’s complaints to management at Wayne Farms do not plead sufficiently severe conditions to support a claim of constructive discharge or knowledge to support a negligent supervision claim.1 Wayne Farms’ position is that its response to the first complaint of misconduct and the lack of opportunity to respond to the second mean that Glanton has failed to state any claim in this case.

In a case in which there is federal claim based on an allegation of harassment by a co-worker, “the employer will be held directly liable if it knew or should have known of the harassing conduct but failed to take prompt remedial action.” Adams v. Austal, U.S.A., L.L.C., 754 F.3d 1240, 1258 (11th Cir. 2014). An employee who complains about harassment by a coworker must prove either actual or constructive knowledge of the

employer. Id. Similarly, under Alabama law, a complaining employee must show that the employer had knowledge of the tortious conduct of the offending employee and failed to take adequate steps to remedy the situation. Potts v. BE & K Const. Co., 604 So. 2d 398, 400 (Ala. 1992). An inadequate response to a complaint also can support a negligent supervision claim. See Stevenson v. Precision Standard, Inc., 762 So. 2d 820, 825 (Ala.

1999) (stating “the manner in which a sexual-harassment complaint is handled when sexual harassment has, in fact, occurred could form the basis for a claim for negligent or wanton supervision.”).

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Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Potts v. BE & K CONST. CO.
604 So. 2d 398 (Supreme Court of Alabama, 1992)
Stevenson v. Precision Standard, Inc.
762 So. 2d 820 (Supreme Court of Alabama, 1999)
Robert Adams v. Austal, USA, LLC
754 F.3d 1240 (Eleventh Circuit, 2014)

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