Hoar v. Prescott Park Arts Festival

CourtDistrict Court, D. New Hampshire
DecidedJanuary 26, 1998
DocketCV-96-551-M
StatusPublished

This text of Hoar v. Prescott Park Arts Festival (Hoar v. Prescott Park Arts Festival) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hoar v. Prescott Park Arts Festival, (D.N.H. 1998).

Opinion

Hoar v . Prescott Park Arts Festival CV-96-551-M 01/26/98 UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

Jonathan R. Hoar

v. Civil N o . 96-551-M

Prescott Park Arts Festival, Inc.

O R D E R

Prescott Park Arts Festival, Inc. (“Prescott Park”) moves to

dismiss Jonathan Hoar’s Title VII suit for lack of subject matter

jurisdiction on grounds that Prescott Park was not an “employer”

within the meaning of 42 U.S.C.A. § 2000e(b) in the applicable

years. For the reasons that follow, Prescott Park’s motion is

granted. Plaintiff’s suit is dismissed.

When subject matter jurisdiction is challenged, the party

invoking federal jurisdiction bears the burden to establish that

jurisdiction exists. Murphy v . United States, 45 F.3d 5 2 0 , 522

(1st Cir. 1995). Here, plaintiff, bears that burden of proof.

When determining subject matter jurisdiction in the context of a

motion to dismiss, the court takes well-pleaded facts in the complaint as true and resolves inferences in favor of the

nonmoving party, but also may consider evidence outside of the

pleadings submitted to support or challenge jurisdictional

allegations. Fed. R. Civ. P. 12(b)(1); Aversa v . United States,

99 F.3d 1200, 1209-10 (1st Cir. 1996). As the court discussed in

its prior order, to meet the Title VII prerequisites for subject

matter jurisdiction, plaintiff must show that Prescott Park had

at least fifteen employees for a minimum of twenty weeks in either 1994 or 1995. See 42 U.S.C.A. § 2000e(b); see also Walters v . Metropolitan Educ. Enterprises, 117 S . C t . 6 6 0 , 663 (1997). A brief case history demonstrates that plaintiff, proceeding pro s e , has had ample opportunity to support his jurisdictional allegations. Prescott Park first moved to dismiss in January 1997 and submitted the affidavit of its president to show that it did not have the jurisdictional minimum number of employees. The court found plaintiff’s response to Prescott Park’s first motion to be inadequate, but allowed plaintiff an additional opportunity to file appropriate materials to support his assertion of federal subject matter jurisdiction. Plaintiff then submitted his own affidavit in which he described certain Prescott Park employees by name, positions, and approximate dates of employment. Because the affidavits left Prescott Park’s employment history somewhat unclear, the court denied the first motion to dismiss, without prejudice to refiling with additional supporting materials. After Prescott Park filed its second motion to dismiss in early October, plaintiff requested and was granted an extension of time (October 27 to December 1 ) , to review Prescott Park’s payroll information and to prepare his objection.

In support of its present motion, Prescott Park has submitted an affidavit of Anita Freedman, president of Prescott Park, as well as copies of its records pertaining to employee wages in 1994 and 1995. The records include summaries for 1994 and 1995, a copy of the ledger for 1994, copies of quarterly New

2 Hampshire and federal employer tax and wage reports for 1994 and 1995, and copies of “Short Run Agreements” with “contractors” for 1995. M s . Freedman represents that the records and summaries submitted are true and accurate, and represent the best payroll information available for 1994 and 1995.

M s . Freedman’s affidavit states that Prescott Park did not employ a minimum of fifteen people for twenty weeks or more during 1994 or 1995. She explains that Prescott Park had a maximum of six1 employees at times during 1994 and also employed a total of fifty-two “independent contractors,”2 fifty of whom

1 Although the affidavit says “six” employees, it lists only five names. Review of the attached and referenced records suggests that M s . Freedman likely intended to include “Sue Bolduc” as one of the six employees. 2 Prescott Park’s designation of “independent contractor” does not necessarily mean that those so designated were not “employees” within the meaning of section 2000e(b). That distinction depends on whether a particular worker meets the requirements of “employee” “under traditional principles of agency law.” Walters, 117 S . C t . at 666 (citing Nationwide Mut. Ins. C o . v . Darden, 503 U.S. 3 1 8 , 323-24 (1992)). Because, based on the record, so few of the group designated as “independent contractors” worked for more than twenty weeks in either 1994 or 1995, it is unnecessary in this case to address the question of their employment status, and neither party has raised the question of whether plaintiff, who is designated an “independent contractor” in 1995 would qualify as an employee for purposes a Title VII action. See, e.g., Serapion v . Martinez, 119 F.3d 982 (1st Cir. 1997) (determining partner not an employee eligible to bring action under Title V I I ) , cert. denied, 1998 WL 6468 (Jan. 1 2 , 1998); Cilecek v . Inova Health System Services, 115 F.3d 256 (4th Cir. 1997) (physician “independent contractor” not employee under Title V I I ) , cert. denied, 1998 WL 6493 (Jan. 1 2 , 1998); Devine v . Stone, Leyton & Gershman, P.C., 100 F.3d 78 (8th Cir. 1996) (plaintiff failed to show that directors and shareholders were employees for Title VII jurisdiction), cert. denied, 117 S . C t . 1694 (1997); Torres Sierra v . Periodico La Perla Del Sur, 842 F. Supp. 6 1 2 , 613 (D.P.R. 1994) (dismissing for lack of subject matter jurisdiction as employer employed “independent contractors” rather than employees).

3 worked for twelve weeks during the summer season from June

through August and two of whom worked for eighteen weeks. Of the

six “employees,” the records summary indicates that only three of

them worked for more than twenty weeks in 1994. The payroll

summary for 1995 designates four people as employees, three of

whom worked for more than twenty weeks, and twenty-eight as

“independent contractors” only one of whom worked for more than

twenty weeks. The “Short Run Agreements” between Prescott Park

and production participants cover the period between June 1 and

August 2 0 , 1995 (or in three cases August 24 or August 2 6 ) , which

is approximately twelve or thirteen weeks. Thus, the materials

submitted support M s . Freedman’s affidavit that Prescott Park did

not have fifteen or more employees for a minimum of twenty weeks

in either 1994 or 1995.

Plaintiff mistakenly argues that Prescott Park has a legal

duty to submit copies of its actual “payroll” for 1994 and 1995

and objects to the motion to dismiss on grounds that Prescott

Park has not provided the necessary information. Plaintiff

misunderstands the jurisdictional burden of proof: as the party

seeking federal jurisdiction, plaintiff must show that subject

matter jurisdiction exists. Prescott Park has no obligation to

prove or disprove jurisdiction.

Despite obtaining a significant extension of time to file

his objection, and having had an opportunity to inspect Prescott

Park’s payroll information before filing his objection, plaintiff

offers little to rebut Prescott Park’s evidence that it did not

4 meet the statutory definition of “employer,” in either 1994 or 1995.

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Related

Aversa v. United States
99 F.3d 1200 (First Circuit, 1996)
United States v. Jose Robles
45 F.3d 1 (First Circuit, 1995)
Karen Devine v. Stone, Leyton & Gershman, P.C.
100 F.3d 78 (Eighth Circuit, 1996)
Freeman v. Federal Deposit Insurance
842 F. Supp. 2 (District of Columbia, 1993)
Cilecek v. Inova Health System Services
115 F.3d 256 (Fourth Circuit, 1997)

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