Mooney v. Roller Bearing Company of America Inc

District Court, W.D. Washington·Decided October 23, 2023·No. 2:20-cv-01030·Unknown

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 9 10 RICHARD MOONEY, CASE NO. 2:20-cv-01030-LK 11 Plaintiff, ORDER REGARDING MOTION 12 v. TO AMEND THE JUDGMENT AND REQUESTING 13 ROLLER BEARING COMPANY OF SUPPLEMENTAL BRIEFING AMERICA, INC., 14 Defendant. 15 16 This matter comes before the Court on Plaintiff Richard Mooney’s motion pursuant to 17 Federal Rule of Civil Procedure Rule 59(e) to alter/amend the judgment to include an award of: 18 (1) liquidated damages, (2) prejudgment interest, (3) post-judgment interest, and (4) a gross up 19 adjustment for adverse tax consequences. Dkt. No. 130. Defendant Roller Bearing Company of 20 America, Inc. (“RBC”) opposes the motion. Dkt. No. 140. For the reasons set forth below, the 21 Court grants the motion in part, denies it in part, defers it in part, and requests supplemental 22 briefing. 23 24 1 I. BACKGROUND 2 After a four-day trial, the jury rendered its verdict, finding that Mooney did not prove that 3 extending his leave was a “substantial factor” in RBC’s decision to lay him off, but did prove that 4 it was a “negative factor” in the decision. Dkt. No. 115 at 1–2. The jury awarded him $160,000 in

5 damages as the reasonable value of wages, salary, and employment benefits lost through December 6 31, 2021. Id. at 2. The Court entered judgment on June 2, 2022. Dkt. No. 116. Additional facts 7 underlying this case have been set forth in prior orders and need not be repeated here except to 8 provide context for specific issues discussed below. 9 II. DISCUSSION 10 Mooney filed this timely motion on June 29, 2022. Dkt. No. 130; see Fed. R. Civ. P. 59(e) 11 (“A motion to alter or amend a judgment must be filed no later than 28 days after the entry of the 12 judgment.”). Mooney seeks to amend the judgment to add additional relief and interest as 13 described below. 14 A. Liquidated Damages

15 Mooney seeks an award of liquidated damages—in an amount equal to the damages 16 awarded by the jury plus prejudgment interest—under both the Family and Medical Leave Act 17 (“FMLA”) and Washington’s Family and Medical Leave Act (“WFMLA”). Dkt. No. 130 at 3. 18 Both statutes provide for such an award as described below.1 19 1) Liquidated Damages under the FMLA 20 Under the FMLA, Mooney is entitled to liquidated damages unless RBC proves, “to the 21 satisfaction of the court,” that its actions that constituted interference with Mooney’s FMLA rights 22

23 1 Mooney seeks a single award of liquidated damages, not a double recovery of liquidated damages under both federal and state law. Dkt. No. 130 at 2 (seeking liquidated damages in “the amount of either $182,547.95 or $169,930.48 (verdict amount + prejudgment interest), depending on the Court’s determination as to which statutory interest rate 24 applies to the claims.”). 1 were “in good faith” and that it “had reasonable grounds for believing that the act or omission was 2 not a violation” of the FMLA. 29 U.S.C. § 2617(a)(1)(A)(iii). There is a “strong presumption” in 3 favor of liquidated damages, and “it is the employer’s burden to overcome this presumption by 4 proving its reasonableness and good faith.” Isom v. JDA Software, Inc., 225 F. Supp. 3d 880, 887

5 (D. Ariz. 2016). If RBC makes that showing, the Court can decline to award liquidated damages 6 or reduce the amount available under the statute. 29 U.S.C. § 2617(a)(1)(A)(iii). 7 To determine if the employer acted in good faith, district courts evaluate the facts based on 8 the “most reasonable interpretation of the jury’s verdict.” Cloutier v. GoJet Airlines, 996 F.3d 426, 9 446 (7th Cir. 2021). Courts cannot disregard the jury’s findings in their decisions on liquidated 10 damages. Atwood v. PCC Structurals, 3:14-cv-00021-HZ, 2015 WL 9480024, at *2 (D. Or. Dec. 11 28, 2015) (“Accepting Defendant’s characterization of these key ‘events,’ however, would require 12 this Court to contradict the jury’s factual findings.”). A court that declines to award liquidated 13 damages must “articulate its reasoning” so the appellate court can “ascertain how the district court 14 exercised its discretion.” Traxler v. Multnomah Cnty., 596 F.3d 1007, 1015–16 (9th Cir. 2010);

15 see also Atwood, 2015 WL 9480024, at *2 (explaining that the court “must make specific findings 16 that the employer’s FMLA violation was in good faith and that the employer had reasonable 17 grounds for believing that its conduct did not violate the FMLA.”). 18 Mooney argues that the Court must conclude that RBC did not act in good faith because 19 the jury found that RBC considered his protected leave as a negative factor in deciding to discharge 20 him, Dkt. No. 130 at 4; see also Dkt. No. 115 at 2, and doing so violated the FMLA. Bachelder v. 21 Am. W. Airlines, 259 F.3d 1112, 1124 (9th Cir. 2001) (an employer’s use of “the taking of FMLA 22 leave as a negative factor in employment actions” violates the FMLA). Therefore, a determination 23 that RBC acted in good faith—despite violating the law—would improperly disregard the jury’s

24 finding. Dkt. No. 130 at 4–5. RBC counters that the damages the jury awarded were effectively 1 front pay because his position was eliminated, and the Court cannot award liquidated damages on 2 front pay awards. Dkt. No. 140 at 7–8. The Court agrees with Mooney. 3 Front pay is future lost wages or an award of damages for lost compensation during the 4 period between judgment and reinstatement or in lieu of reinstatement. See Traxler, 596 F.3d at

5 1009 n.1; see also Pollard v. E.I. du Pont de Nemours & Co., 532 U.S. 843, 846 (2001). The jury’s 6 verdict did not include an award for front pay and explicitly stated that the damages it awarded 7 represented Mooney’s “damages related to the reasonable value of wages, salary and employment 8 benefits lost up to December 31, 2021” that were proximately caused by RBC’s conduct. Dkt. No. 9 115 at 2 (emphasis added).2 Nor could the jury have awarded front pay because the Court—not 10 the jury—decides both the availability of front pay and the amount of a front pay award under the 11 FMLA. Traxler, 596 F.3d at 1011. Mooney did not request, and the Court did not award, front pay. 12 In the same vein, RBC argues that “[a]n award representing pay that a plaintiff would have 13 received up until the time they were furloughed is best characterized as front pay.” Dkt. No. 140 14 at 6. Even if that were true, Mooney was not furloughed, and there was no evidence that he would

15 have been furloughed on December 31, 2021, the end date of his damages. Dkt. No. 115 at 2. 16 RBC also argues that it acted in good faith because it eliminated Mooney’s position for 17 financial reasons. Dkt. No. 140 at 7–9.3 The jury was not required to believe RBC’s testimony to 18 that effect, and it apparently rejected it at least in part by concluding that RBC considered 19 Mooney’s FMLA leave a negative factor in the layoff decision. See, e.g., Traxler v. Multnomah 20 Cnty., No. 06-1450-KI, 2010 WL 3069340, at *1 (D. Or. Aug. 2, 2010) (rejecting the employer’s 21

22 2 At RBC’s request, the Court deleted from the proposed jury instructions and verdict form references to future economic damages, Dkt. No.

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