Goodson v. Nasco Healthcare Inc

CourtDistrict Court, N.D. Texas
DecidedNovember 19, 2024
Docket3:21-cv-01467
StatusUnknown

This text of Goodson v. Nasco Healthcare Inc (Goodson v. Nasco Healthcare Inc) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Goodson v. Nasco Healthcare Inc, (N.D. Tex. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

RUSH GOODSON, § § Plaintiff, § § v. § Civil Action No. 3:21-CV-01467-N § NASCO HEALTHCARE INC., § § Defendant. §

MEMORANDUM OPINION AND ORDER

This Order addresses Defendant Nasco Healthcare Inc.’s (“Nasco”) motion to reconsider [95] the Court’s Order denying Nasco’s motion for summary judgment [79]. It also addresses Plaintiff Rush Goodson’s motion for leave to file a sur-reply [129]. Because Nasco has not provided a sufficient reason for the Court to reconsider its summary judgment decision, the Court denies the motion to reconsider. The Court then denies Goodson’s motion for leave to file a sur-reply as moot. I. ORIGINS OF THE DISPUTE This case arises from a dispute between Goodson and Nasco over alleged unpaid commissions. Nasco operates in the healthcare industry as a manufacturer in direct sales and distribution of medical products. Pl.’s Am. Compl. ¶ 8 [33]. Nasco employed three salespeople: Angela Hoenig, Matt Long, and Goodson. Id. ¶ 10. Hoenig and Long resigned from their employment after Nasco allegedly failed to pay owed commissions. Id. As a result, Nasco and Goodson began negotiations for him take on new responsibilities and alter his compensation structure. Id. ¶ 11. The parties failed to reach an agreement, and Nasco terminated Goodson’s employment in April 2021. Id. ¶ 12. Previously, Nasco moved for summary judgment on all claims. Def.’s Mot. Sum.

J. [43]. The Court denied this motion. Order, Sept. 11, 2023 [79]. Nasco now moves for reconsideration of this order denying summary judgment. Def.’s Br. 3 [96]. Specifically, it seeks reconsideration of summary judgment as to Goodson’s breach of contract claim based on the decision of another district court in a case filed by Matt Long. Id. at 4. It also seeks reconsideration of summary judgment as to Goodson’s fraudulent concealment claim

because additional discovery was conducted, and because another district court granted summary judgment against Angela Hoenig on her similar claim. Id. at 12, 16. II. LEGAL STANDARDS A. Reconsideration Standard

Federal Rule of Civil Procedure 54(b) empowers courts to reconsider any order issued before judgment is entered. FED. R. CIV. P. 54(b) (stating that “any order . . . that adjudicates fewer than all the claims . . . of fewer than all the parties . . . may be revised at any time before the entry of a judgment”); Saqui v. Pride Cent. Am., LLC, 595 F.3d 206, 210–11 (5th Cir. 2010) (noting that “when a district court rules on an interlocutory order, it is ‘free to reconsider and reverse its decision for any reason it deems sufficient, even in

the absence of new evidence or an intervening change in or clarification of the substantive law’” (quoting Lavespere v. Niagara Mach. & Tool Works, Inc., 910 F.2d 167, 185 (5th Cir. 1990), abrogated on other grounds by Little v. Liquid Air Corp., 37 F.3d 1069, 1075 n.14 (5th Cir. 1994) (en banc))). “Although the precise standard for evaluating a motion to reconsider under Rule 54(b) is unclear, whether to grant such a motion rests within the discretion of the court.” Dos Santos v. Bell Helicopter Textron Inc. Dist., 651 F. Supp. 2d 550, 553 (N.D. Tex.

2009). The standard is less exacting than that applied when analyzing a motion to amend a judgment under Rule 59 or a motion for relief from judgment under Rule 60. Id. But similar considerations should be entertained, such as “whether the movant is attempting to rehash its previously made arguments or is attempting to raise an argument for the first time without justification.” Id.

B. Issue Preclusion Standard

Issue preclusion, or collateral estoppel, prohibits relitigation of issues previously decided in another proceeding. It applies when “(1) the identical issue was previously adjudicated; (2) the issue was actually litigated; and (3) the previous determination was necessary to the decision.” Pace v. Bogalusa City Sch. Bd., 403 F.3d 272, 290 (5th Cir. 2005) (en banc). For issue preclusion to apply, “both the facts and the legal standard used to assess them” must be identical. Copeland v. Merrill Lynch & Co., 47 F.3d 1415, 1422 (5th Cir. 1995). Generally, nonparties cannot be precluded by a prior decision. Taylor v. Sturgell, 553 U.S. 880, 892–93 (2008). However, there are exceptions to this rule, including

situations where the nonparty controlled the prior litigation and where the nonparty was adequately represented in the prior litigation. Id. at 894–95. “Control” for this purpose “‘requires that a person have effective choice as to the legal theories and proofs to be advanced in behalf of the party to the action’ and ‘have control over the opportunity to obtain review.’” Students for Fair Admissions, Inc. v. Univ. of Tex., 37 F.4th 1078, 1087 (5th Cir. 2022) (quoting Benson & Ford, Inc. v. Wanda Petroleum Co., 833 F.2d 1172, 1174 (5th Cir. 1987)). Adequate representation requires alignment of interests between the

nonparty and representative and that the representative “understood herself to be acting in a representative capacity or the original court took care to protect the interests of the nonparty.” Taylor, 553 U.S. at 900. III. THE COURT DENIES THE MOTION TO RECONSIDER

To prevail on a motion to reconsider, Nasco must show that there exists a sufficient reason for the Court to reverse its prior ruling. Having reviewed the briefs, the Court finds Nasco has not shown such a reason. A. The Court Declines to Reconsider Denying Summary Judgment on Goodson’s Breach of Contract Claim

Nasco’s motion for reconsideration is based primarily on the decision of another court in Long v. Nasco Healthcare, Inc., 2024 WL 1376371, at *1 (N.D. Ill. 2024), in which the court granted summary judgment for Nasco on all claims. Nasco argues Long’s claims for breach of contract are “substantially identical” to Goodson’s and urges this Court to reconsider its denial of summary judgment. Def.’s Br. 6–9. However, Nasco’s arguments are mosty a rehashing of its previously denied summary judgment arguments. Further, the Long court’s decision does not have issue-preclusive effect on Goodson. Nasco first argues that the terms of Goodson’s and Long’s compensation agreements are “substantially identical.” Def.’s Br. 6. Then, Nasco urges the Court to

reconsider denying summary judgment on Goodson’s breach of contract claim because the court in Long granted summary judgment for Nasco on Long’s similar claim. Id. at 7. In making this argument however, Nasco simply rehashes the same underlying arguments it made in its original motion for summary judgment. Compare id. at 8 (arguing the evidence

shows that Goodson knew he would only be paid on Wisconsin sales he procured and about which he notified his manager), with Def.’s Mot. Summ. J. 18 [43] (same); compare Def.’s Br. 9 (arguing Goodson knew he was not entitled to commissions on OEM sales), with Def.’s Mot. Summ. J. 19 (same).

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Related

Little v. Liquid Air Corp.
37 F.3d 1069 (Fifth Circuit, 1994)
Pace v. Bogalusa City School Board
403 F.3d 272 (Fifth Circuit, 2005)
Saqui v. Pride Central America, LLC
595 F.3d 206 (Fifth Circuit, 2010)
Taylor v. Sturgell
553 U.S. 880 (Supreme Court, 2008)
Dos Santos v. Bell Helicopter Textron, Inc. District
651 F. Supp. 2d 550 (N.D. Texas, 2009)
Students for Fair Admissions v. Univ of TX
37 F.4th 1078 (Fifth Circuit, 2022)
Copeland v. Merrill Lynch & Co.
47 F.3d 1415 (Fifth Circuit, 1995)
Lavespere v. Niagara Machine & Tool Works, Inc.
910 F.2d 167 (Fifth Circuit, 1990)

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Bluebook (online)
Goodson v. Nasco Healthcare Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/goodson-v-nasco-healthcare-inc-txnd-2024.