Mack v. United Parcel Service, Inc.

CourtDistrict Court, S.D. Alabama
DecidedApril 28, 2025
Docket1:24-cv-00369
StatusUnknown

This text of Mack v. United Parcel Service, Inc. (Mack v. United Parcel Service, Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mack v. United Parcel Service, Inc., (S.D. Ala. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION KENDRICK MACK, et al., ) ) Plaintiffs, ) ) v. ) CIVIL ACTION NO. 24-00369-JB-N ) UNITED PARCEL SERVICE, INC., ) ) Defendant. )

ORDER This action is before the Court on Defendant United Parcel Service, Inc.’s Motion for Judgment on the Pleadings and incorporated brief in support thereof (Doc. 23), Plaintiffs’ Response (Doc. 27) and Defendant’s Reply (Doc. 29). After consideration of the record and for the reasons set forth hereinbelow, Defendant’s motion is DENIED. I. Factual and Procedural Background On October 7, 2024, Plaintiffs, Kendrick Mack, Renicia Reed, Trayvond Cooper, Brian Russell, Diai Raheem, David Bassa, and Marquiesta Evans (collectively “Plaintiffs”) filed a complaint against Defendant, United Parcel Service Inc. (“UPS”) asserting claims for race discrimination pursuant to 42 U.S.C. § 1981 and Title VII. (Doc. 1). According to the Complaint, Plaintiffs are all Black employees who have been subject to ongoing, systemic, and unlawful race discrimination during their employment and under the supervision of Caleb Ashcraft, a white manager. (Id.). Shortly after filing its Answer (Doc. 21), Defendant filed the instant Motion for Judgment on the Pleadings and incorporated brief (Doc. 23). Therein, Defendant argues that Plaintiffs’ complaints simply restate their grievances which were previously adjudicated under the Framework of the Collective Bargaining Agreement (“CBA”), and can only be filed as ULPs (unfair labor practice charge) with the National Labor Relations Board (“NLRB”). (Doc. 23). In

short, Defendant contends that because the Complaint alleges violations of the CBA, this action is under the exclusive jurisdiction of the NLRB per what is known as the Garmon pre-emption doctrine. (Id.). Alternatively, Defendant seeks dismissal pursuant to Federal Rule 12(b)(6) for failure to state a claim upon which relief can be granted. Plaintiffs argue that this action does not ask this Court to interpret or enforce the CBA and oppose the application of the Garmon pre- emption doctrine. Additionally, they argue they have properly stated claims upon which relief

can be granted. (Doc. 27).1 A hearing was held on March 12, 2025, and the matter is ripe for adjudication. II. Legal Standard A party may file a motion for judgment on the pleadings after the pleadings are closed but within such time as not to delay trial. Fed.R.Civ.P. 12(c). “Judgment on the pleadings is

appropriate when there are no material facts in dispute, and judgment may be rendered by considering the substance of the pleadings and any judicially noticed facts.” Hawthorne v. Mac Adjustment, Inc., 140 F.3d 1367, 1370 (11th Cir. 1998) (citing Fed.R.Civ.P.12(c)). The legal standard for assessing a motion for judgment on the pleadings under Rule 12(c) is the same as the standard for a motion to dismiss under Rule 12(b)(6). U.S. v. Bahr, 275 F.R.D. 339, 340 (M.D. Ala. June 22, 2011). The main difference between the motions is that a motion for judgment on

1 The majority of Plain1ffs’ response deals with the ability of Defendant to compel arbitra1on of their race-based claims. However, Defendant does not seek to compel arbitra1on, and the Court will not address that issue in this order. the pleadings is made after an answer and that answer may also be considered in deciding the motion. (Id.)

When reviewing a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), the Court must view the allegations in the light most favorable to the plaintiff and accept the allegations of the complaint as true. Speaker v. U.S. Dep't of Health & Human Servs., 623 F.3d 1371, 1379 (11th Cir. 2010). To avoid dismissal, a complaint must contain sufficient factual allegations to “state a claim to relief that is plausible on its face” and “raise a right to relief above

the speculative level.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555, 570 (2007). “While a complaint attacked by a Rule 12(b)(6) motion to dismiss does not need detailed factual allegations, a plaintiff's obligation to provide the grounds of his entitle[ment] to relief requires more than labels and conclusions, and a formulaic recitation of a cause of action’s elements will not do.” Twombly, 550 U.S. at 555 (alteration in original) (citations and quotations omitted). The Court should not assess “whether a plaintiff will ultimately prevail but” consider “whether the

claimant is entitled to offer evidence to support the claims.” Id. at 583 (citing Scheuer v. Rhodes, 416 U.S. 232, 236 (1974)). III. Analysis A. The Garmon Preemption Doctrine and Judgment on the Pleadings

There is no dispute here, that five of the named plaintiffs were members of the International Brotherhood of Teamsters (“Union”) or that a CBA between the Union and the Defendant governs their employment. As a result, the relevant dispute is whether Plaintiffs claims are barred by the doctrine set forth in San Diego Building Trades Council v. Garmon, 359 U.S. 236, 79 S.Ct. 773, 3 L.Ed.2d 775 (1959), (the “Garmon preempeon” doctrine). The United States Supreme Court has recognized that Congress implicitly mandated two types of pre-empeon necessary to implement federal labor policy. Chamber of Commerce of U.S. v. Brown, 554 U.S. 60, 128 S.Ct. 2408, 171 L.Ed.2d 264 (2008). Relevant here, the Garmon pre-

empeon, “is intended to preclude state interference with the Naeonal Labor Relaeons Board's interpretaeon and aceve enforcement of the ‘integrated scheme of regulaeon’ established by the NLRA.” Id. at 65 quoeng Golden State Transit Corp. v. Los Angeles, 475 U.S. 608, 613, 106 S.Ct. 1395, 89 L.Ed.2d 616 (1986) (Golden State I). As such, Garmon pre-empeon forbids States to “regulate acevity that the NLRA protects, prohibits, or arguably protects or prohibits.” Id. quoeng Wisconsin Dept. of Industry v. Gould Inc., 475 U.S. 282, 286, 106 S.Ct. 1057, 89 L.Ed.2d 223 (1986).

While the Court appreciates Defendant’s efforts to persuade it otherwise, the Court is not compelled by Defendant’s position. First, and importantly, on its face, Garmon pre-empts state causes of action which arguably conflict with the NLRA. This case, however, only asserts federal causes of action and as a result, it falls outside the traditional scope of Garmon pre-emption. Second, the Eleventh Circuit has yet to determine whether the Garmon preemption doctrine

applies to pre-empt federal causes of action brought pursuant to either § 1981 or Title VII. As a result, there is no binding authority on the application of the Garmon pre-emption doctrine to cases similar to this one.

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