Janice M. Crawford v. Pamela Bondi, Attorney General, U.S. Department of Justice

CourtDistrict Court, W.D. Tennessee
DecidedJanuary 29, 2026
Docket2:23-cv-02456
StatusUnknown

This text of Janice M. Crawford v. Pamela Bondi, Attorney General, U.S. Department of Justice (Janice M. Crawford v. Pamela Bondi, Attorney General, U.S. Department of Justice) is published on Counsel Stack Legal Research, covering District Court, W.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Janice M. Crawford v. Pamela Bondi, Attorney General, U.S. Department of Justice, (W.D. Tenn. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TENNESSEE WESTERN DIVISION

) JANICE M. CRAWFORD, ) ) Plaintiff, ) ) ) v. ) No. 2:23-cv-02456-SHM-atc ) PAMELA BONDI, ATTORNEY ) GENERAL, U.S. DEPARTMENT OF ) JUSTICE ) ) Defendant.

ORDER Before the Court is Defendant’s “Motion to Strike or Disregard Paragraphs 2-3 and 12-15 of Steve Moody’s Sham Declaration.” (ECF No. 94.) For the reasons below, the Court GRANTS IN PART and DENIES IN PART Defendant’s Motion.

I. Background Plaintiff’s Complaint alleges employment discrimination under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e, as amended by §1981a (“Title VII”). (ECF No. 1.) Plaintiff alleges that the U.S. Department of Justice discriminated against her by retaliating against her for engaging in a protected activity as defined by Title VII. (Id.) Specifically, Plaintiff alleges that the Department of Justice refused to hire her for an Administrative Officer (“AO”) position in Seattle because of her prior EEO activity. (Id.) On August 20, 2025, Defendant moved

for summary judgment. (ECF No. 75.) On October 7, 2025, Plaintiff filed her Response, including an additional declaration by a witness, Steven Moody (the “Moody Declaration”). (ECF Nos. 83 and 83-1.) On December 4, 2025, Defendant filed the “Motion to Strike or Disregard Paragraphs 2-3 and 12-15 of Steve Moody’s Sham Declaration.” (ECF No. 94.) Plaintiff responded to the Motion on December 22, 2025. (ECF No. 98.)

II. Law Defendant titles its Motion “Motion to Strike or Disregard…” portions of the Moody Declaration. (ECF No 94.) Defendant cites relevant caselaw, but does not cite the rules of civil procedure under which it brings its Motion. (Id.) The Federal Rules of Civil Procedure provide no grounds to strike documents that are not pleadings. See Fed. R. Civ. P.

12(f) (“The court may strike from a pleading…”); see also Fox v. Michigan State Police Dep’t, 173 F. App’x 372, 375 (6th Cir. 2006) (“Under Fed. R. Civ. P. 12(f), a court may strike only material that is contained in the pleadings”); and Benoist v. Titan Med. Mfg., LLC, No. 219CV02704SHMTMP, 2021 WL 1723235, at *1 (W.D. Tenn. Apr. 30, 2021) (“The Federal Rules of Civil Procedure do not provide for a motion to strike documents or portions of documents other than pleadings”).

The Rules of Civil Procedure define “pleading” as a complaint, an answer to a complaint, an answer to a counterclaim designated as a counterclaim, an answer to a crossclaim, a third- party complaint, an answer to a third-party complaint, and, if the court orders one, a reply to an answer. Fed. R. Civ. P. 7(a). Declarations attached as exhibits to summary judgment responses are not pleadings. Therefore, the Court cannot “strike” the paragraphs Defendant contests. The Motion also asks the Court to “disregard” select paragraphs of Moody’s Declaration. (ECF No. 94.) In the body of the Motion, Defendant appears to limit its request to the Court’s

consideration of Defendant’s summary judgment motion. “Because ¶¶ 2-3 and 12-15 of Moody’s declaration directly contradict his deposition testimony, the Court should strike or disregard these paragraphs when it considers the [Defendant’s] motion for summary judgment.” (ECF No. 94 at 7.) Federal Rule of Civil Procedure 56 governs summary judgment. Fed. R. Civ. P. 56. Rule 56(c)(2) allows parties to “object that material cited to support or dispute a fact cannot be presented in a form that would be admissible in evidence.” Fed. R. Civ. P. 56(c)(2). The 2010 amendment notes provide that Rule 56(c)(2) objections “[f]unction much as an objection at trial, adjusted for the pretrial setting…There is no need to make a

separate motion to strike.” Fed. R. Civ. P. 56. Nonetheless, courts considering similar motions have held that, “[i]f a party does file a separate motion to strike, the motion should be construed as an objection under Rule 56(c)(2).” P.F. v. Gordon, No. 3:15CV01923, 2018 WL 2149280, at *3 (N.D. Ohio May 10, 2018), citing Stillwagon v. City of Delaware, 274 F. Supp. 3d 714, 737 (S.D. Ohio 2017). In P.F. v. Gordon, the Court decided a similar motion that asked the court to “strike” allegedly contradictory or “sham” declarations that the plaintiff included in the response to a defendant’s motion for summary judgment. 2018 WL 2149280. There, the Court construed the “motion to strike” as an objection under Rule 56(c)(2) and decided which paragraphs of

the declarations could be considered when the court decided the summary judgment motion. Id. The Court construes Defendant’s “Motion to Strike or Disregard” as an objection under Rule 56(c)(2) and will determine whether to consider the disputed paragraphs of the Moody Declaration when it decides Defendant’s motion for summary judgment. Although Defendant’s motion for summary judgment was filed first, “[g]enerally, a district court should dispose of motions that affect the record on summary judgment before ruling on the parties' summary judgment motions.” Brainard v. Am. Skandia Life Assur. Corp., 432 F.3d 655, 667 (6th Cir. 2005). The Court

will decide Defendant’s “Motion to Strike or Disregard…” before ruling on Defendant’s motion for summary judgment.

III. Analysis - Sham Affidavit Rule 56(c)(1)(A) allows parties seeking or opposing summary judgment to cite materials in the record, including “affidavits or declarations.” Fed. R. Civ. P. 56(c)(1)(A). The Moody Declaration, which Plaintiff attaches to her response to Defendant’s motion for summary judgment, would ordinarily be allowable under this rule.

Defendant argues, however, that the Moody Declaration violates the “sham affidavit” rule. (ECF No. 94 at 2.) That rule “embodies the common-sense conclusion that a party may not create a factual issue by filing an affidavit, after a motion for summary judgment has been made, which contradicts his earlier deposition testimony.” Cox v. Ruckel, No. 23-5698, 2025 WL 2603787, at *8 (6th Cir. Sept. 9, 2025) (cleaned up). The Sixth Circuit has said that the rule applies in two situations. It can apply when a witness’s affidavit “directly contradicts the witness’s prior testimony,” and it can apply when the witness’s

affidavit is “in tension with that prior testimony” so as to create a “sham issue.” Boykin v. Fam. Dollar Stores of Michigan, LLC, 3 F.4th 832, 842 (6th Cir. 2021) (citing Aerel, S.R.L. v. PCC Airfoils, L.L.C., 448 F.3d 899 (6th Cir. 2006)). Courts in

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Bluebook (online)
Janice M. Crawford v. Pamela Bondi, Attorney General, U.S. Department of Justice, Counsel Stack Legal Research, https://law.counselstack.com/opinion/janice-m-crawford-v-pamela-bondi-attorney-general-us-department-of-tnwd-2026.