Lynch v. Wal-Mart Associates, Inc.

CourtDistrict Court, District of Columbia
DecidedFebruary 8, 2024
DocketCivil Action No. 2020-0934
StatusPublished

This text of Lynch v. Wal-Mart Associates, Inc. (Lynch v. Wal-Mart Associates, Inc.) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lynch v. Wal-Mart Associates, Inc., (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

PAULA LYNCH,

Plaintiff, Civil Action No. 20-934

v. Judge Beryl A. Howell

WAL-MART ASSOCIATES, INC.,

Defendant.

MEMORANDUM OPINION

Following a three-day trial, a jury returned a verdict, on August 9, 2023, in favor of the

defendant Wal-mart Associates, Inc. (“Wal-mart”), on claims brought by plaintiff Paula Lynch

on behalf of the Estate of her daughter Diamond Lynch, for violations of the District of

Columbia Human Rights Act (“DCHRA”), D.C. Code §§ 2-1401 et seq., and the Protecting

Pregnant Workers Fairness Act (“PPWFA”), D.C. Code § 21-1231 et seq. See Verdict Form,

ECF No. 62; Minute Order (April 8, 2022) (granting Paula Lynch’s unopposed motion to

substitute for plaintiff-decedent Diamond Lynch). While plaintiff was ably represented by

counsel both before and at trial, she is now proceeding pro se. Pending before the Court are

defendant’s Bill of Costs, ECF No. 65, to which plaintiff, while counseled, filed objections, Pl.’s

Opp’n to Def.’s Bill of Costs, ECF No. 75-1, and plaintiff’s pro se “Motion for Reconsideration”

[of the Clerk’s Entry of Judgment], ECF No. 67, as amended, ECF No. 71, which invokes

Federal Rules of Civil Procedure 59 and 60(b) as the procedural grounds for relief, id. at 1. For

the following reasons, plaintiff’s motion for a new trial or other relief from the jury verdict in

defendant’s favor is denied, and defendant’s Bill of Costs is granted.

1 I. BACKGROUND

Plaintiff Diamond Lynch brought this action in D.C. Superior Court in February 2020,

alleging violations of the DCHRA by defendant, her former employer. See Def.’s Notice of

Removal at 1–2, ECF No. 1. Following removal to this Court, plaintiff filed an amended

complaint, reaffirming her claims under the DCHRA and adding claims under the PPWFA. Am.

Compl. at 1, ECF No. 18. Defendant filed a motion for summary judgment in April 2021, which

this Court granted in part, as to plaintiff’s retaliation claim brought under the PPWFA, see

Minute Order (March 8, 2022), but denied as to plaintiff’s claims of discrimination under the

DCHRA, see Minute Order (March 8, 2022). By this time, plaintiff Diamond Lynch had passed

away, and her mother, plaintiff Paula Lynch, filed a consent motion to substitute on her behalf in

this litigation, which this Court granted by minute order in April 2022. See Minute Order (April

8, 2022).

Less than three weeks before a trial was scheduled to begin in this case, defendant filed

an Emergency Motion to Dismiss the case, on the basis that defendant learned only at the pretrial

conference on July 14, 2023 that plaintiff-decedent had died due to a drug overdose, and that

both plaintiff-decedent and plaintiff had “fail[ed] to supplement discovery responses with

information that Decedent Lynch suffered another non-fatal drug overdose” five days prior to her

deposition in the case. Def.’s Emergency Mot. for Sanction of Dismissal with Prejudice (“Def.’s

Emergency Mot.”) at 1, ECF No. 48. Defendant claimed that this failure deprived them of “an

opportunity to adequately prepare its defenses to her claims for damages, including her claim for

emotional distress damages, and to depose and/or cross-examine Decedent Lynch.” Id. After

hearing argument on defendant’s motion, this Court denied defendant’s Emergency Motion to

Dismiss, see Minute Order (July 28, 2023), because “the sanction of dismissal . . . was

2 unwarranted, given other information already disclosed to defendant providing significant clues

as to Diamond Lynch’s use of illicit drugs, such as plaintiff’s cause of death reflected on her

death certificate.” Minute Order (Aug. 9, 2023). Instead, defendant was permitted an

opportunity for additional discovery before trial to permit defendant to investigate Diamond

Lynch’s history of drug use during the relevant timeframe and reopened fact discovery for a

limited period, from July 28, 2023 to August 4, 2023, for further inquiry only as to plaintiff-

decedent’s drug use. See Minute Order (July 28, 2023). Defendant conducted another

deposition of plaintiff during this timeframe, to inquire into her knowledge of plaintiff-

decedent’s drug use. See Def.’s Reply to Pl’s Opp’n to Def.’s Bill of Costs at 5, ECF No. 77.

This case then proceeded to trial as scheduled on August 7, 2023. 1

1 Despite this last-minute flurry of motion practice and discovery over plaintiff-decedent’s drug abuse and overdoses, this issue anticipated by both sides was never raised during trial. Indeed, prompted by defendant’s motion to dismiss, plaintiff moved to “prohibit Defendant from implying or arguing that Ms. Lynch’s drug use makes her dishonest or not credible merely because she used drugs at some time in the past” and “requir[ing] Defendant to establish a foundation before allowing it to impeach Ms. Lynch’s credibility with the suggestion that she was under the influence of drugs when she was fired or when she testified at her deposition.” Pl.’s Mem. in Supp. of Mot. in Limine to Exclude Evidence at 1, ECF No. 52-1. Defendant responded that resolving plaintiff’s motion in limine prior to trial would be “premature,” Def.’s Opp’n to Pl.’s Mot. in Limine to Exclude Evidence at 1– 3, ECF No. 53, “essentially handing plaintiff a victory on her motion,” Minute Order (Aug. 9, 2023), and thus ruling was reserved, with the Court instructing the parties prior to opening statements not to discuss the issues presented in plaintiff’s motion in limine until defendant alerted the Court of a change of defendant’s position and that the motion should be resolved, Minute Order (Aug. 9, 2023). Only after both sides rested, defendant requested, during the charging conference, consideration of its proposed jury instruction regarding a permitted inference for plaintiff’s failure to supplement discovery by producing information about Diamond Lynch’s use of illicit drugs in November 2020 and April 2021. Id. This requested jury instruction was denied since defendant never put at issue during the evidentiary portion of the trial either plaintiff’s failure to supplement discovery and produce this information or Diamond Lynch’s use of illicit drugs during the relevant timeframe. Id. The Court also denied plaintiff’s motion in limine as moot. Id.

3 After a three-day trial, a jury returned a verdict in favor of defendant, on August 9, 2023.

Plaintiff filed a Motion for Reconsideration, ECF No. 67, on September 6, 2023, as amended in

her Final Amended Motion for Reconsideration, ECF No. 71. Plaintiff requests a new trial for

several reasons, including allegations that defendant and its witnesses committed “misconduct,

hijinks, and fraud” throughout the course of the trial. Pl.’s Final Amended Motion for

Reconsideration (“Pl.’s Amended Mot.”) at 1. In addition to plaintiff’s motion for a new trial,

defendant’s Bill of Costs is ripe for decision. Def.’s Bill of Costs, ECF No. 65.

II. LEGAL STANDARDS

A. Federal Rule of Civil Procedure 59

Federal Rule of Civil Procedure

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