Nelson v. Harris United, LLC

CourtDistrict Court, N.D. Oklahoma
DecidedJanuary 5, 2023
Docket4:22-cv-00384
StatusUnknown

This text of Nelson v. Harris United, LLC (Nelson v. Harris United, LLC) is published on Counsel Stack Legal Research, covering District Court, N.D. Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nelson v. Harris United, LLC, (N.D. Okla. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OKLAHOMA MATT NELSON, individually and on behalf ) of all others similarly situated, ) ) Plaintiff/Counter Defendant, ) ) v. ) Case No. 22-CV-0384-CVE-CDL ) HARRIS UNITED, LLC, ) ) Defendant/Counter Plaintiff. ) OPINION AND ORDER Before the Court are plaintiff’s opposed motion for leave to file a first amended complaint (Dkt. # 30), and defendant’s response (Dkt. # 35). The deadline for plaintiff to file a reply to defendant’s response has expired, and plaintiff has not filed a reply. Plaintiff moves the Court for leave to amend his complaint, pursuant to Fed. R. Civ. P. 15, in order to add a claim for retaliation under the Fair Labor Standards Act (FLSA) based on defendant’s counterclaims. Dkt. # 30, at 1-2. Defendant opposes plaintiff’s motion to amend as futile, arguing that the proposed retaliation claim fails as a matter of law. Dkt. # 35, at 2. On September 2, 2022, plaintiff filed this collective action alleging wage and hour violations under the FLSA. Dkt. # 2. On October 14, 2022, defendant filed an answer to plaintiff’s complaint (Dkt. # 9), and filed counterclaims against plaintiff for breach of fiduciary duty and conversion under Oklahoma state law (Dkt. # 10). On October 28, 2022, plaintiff moved to dismiss defendant’s counterclaims for lack of jurisdiction. Dkt. # 19. Plaintiff has abandoned that motion to dismiss defendant’s counterclaims (Dkt. # 29) and, instead, answered the counterclaims (Dkt. # 31). In addition, plaintiff now brings this motion for leave to file an amended complaint to add a claim of retaliation under the FLSA (Dkt. # 30). Under Fed. R. Civ. P. 15(a)(2), after the opposing party has served a responsive pleading, “a party may amend its pleadings only with the opposing party’s written consent or the court’s leave.” Minter v. Prime Equipment Co., 451 F.3d 1196, 1204 (10th Cir. 2006). The decision to grant leave to amend is within the discretion of the district court but, when leave is sought, it should be “freely

given when justice so requires.” Bradley v.Val-Majias, 379 F.3d 892, 900-91 (10th Cir. 2004). Leave to amend may be denied if the proposed amendment would be futile and would not survive a motion to dismiss under Fed. R. Civ. P. 12(b)(6). Jefferson County Sch. Dist. No. R-1 v. Moody’s Investor’s Services, Inc., 175 F.3d 848, 859 (10th Cir. 1999). Denial of a motion to amend may also be appropriate if the moving party unduly delayed when seeking leave to amend and has no adequate explanation for the delay. Minter, 451 F.3d at 1206. “In the Tenth Circuit, untimeliness alone is an adequate reason to refuse leave to amend.” Duncan v. Manager, Dep’t of Safety, City and County

of Denver, 397 F.3d 1300, 1315 (10th Cir. 2005). The issue here is whether amending the complaint would be futile. Plaintiff contends that the filing of counterclaims can amount to retaliatory conduct under the FLSA, and, therefore, the addition of a retaliation claim is warranted. Dkt. # 30. Defendant argues that its counterclaims cannot constitute an adverse employment action as a matter of law because they are cognizable claims and, therefore, “not frivolous, baseless, or otherwise abusive.” Dkt. # 35, at 6. The FLSA expressly prohibits an employer from retaliating against an employee for reporting alleged violations:

[I]t shall be unlawful for any person . . . to discharge or in any other manner discriminate against any employee because such employee has filed any complaint or instituted or caused to be instituted any proceeding under or related to this chapter, or has testified or is about to testify in any such proceeding . . . . 2 29 U.S.C. § 215(a)(3). To make a prima facie case of FLSA retaliation, a plaintiff must show that “(1) [he] engaged in protected activity under the FLSA, (2) [he] suffered an adverse employment action contemporaneous with or subsequent to the protected activity, and (3) a causal connection between the protected activity and the adverse employment action.” Pacheco v. Whiting Farms, Inc., 365 F.3d 1199, 1206 (10th Cir. 2004). An adverse employment action means that “the employer’s actions must be harmful to the point that they could well dissuade a reasonable worker from making or supporting a charge of discrimination.” Burlington Northern & Santa Fe Ry. Co. v. White, 548 U.S. 53, 57 (2006). In addition, “[flormer employees qualify as ‘employees’ for purposes of bringing unlawful retaliation claims against a former employer. Trujillo v. Univ. of Colorado Health Scis. Ctr., 157 F.3d 1211, 1215 (10th Cir. 1998) (citing Robinson v. Shell Oil Co., 519 U.S. 337, 346 (1997)). Defendant argues that plaintiff's motion to amend his complaint with a retaliation claim is futile because plaintiff did not suffer an adverse employment action, as a matter of law. The Tenth Circuit Court of Appeals has yet to address whether the filing of a counterclaim can constitute an adverse employment action to support a retaliation claim. See Timmerman v, U.S. Bank, N.A., 483 F.3d 1106, 1123 (10th Cir. 2007) (“While it is certainly an interesting question whether the filing of counterclaims in response to discrimination claims brought by a former employee constitutes an adverse employment action, that question . . . need not be decided in this case.”). Other district courts in the Tenth Circuit have held that “the mere assertion of a counterclaim does not constitute the requisite adverse employment action.” Feltner_v. Dragonfly Ent. Grp., LLC, No. 21-CV-03052-LTB-STV, 2022 WL 2187793, at *2 (D. Colo. June 13, 2022) (citing cases).

At least one court in the Tenth Circuit entertained the possibility that a counterclaim may constitute an adverse employment action under some circumstances. See, Robinson v. Dean Foods Co., No. 08-CV-01186-REB-CBS, 2009 WL 2382764, at 5* (D. Colo. July 30, 2009) (“It is conceivable that a frivolous, baseless, or otherwise abusive counterclaim might form the basis for

a retaliation claim.”). However, Robinson, the lone case cited by plaintiff in support of his motion, held that the counterclaim at issue could not satisfy the adverse employment action standard. As the court explained: When an employee initiates the litigation, a counterclaim cannot dissuade the employee from making a charge of discrimination . . . because the charge must necessarily be made before the employer can file a counterclaim. Thus, a counterclaim falls within the Burlington Northern definition of adverse action only if the counterclaim “could well dissuade a reasonable worker from . . . supporting a charge of discrimination.” Robinson, 2009 WL 2382764, at *4 (quoting Burlington Northern, 548 U.S. at 57).

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Related

Robinson v. Shell Oil Co.
519 U.S. 337 (Supreme Court, 1997)
Pacheco v. Whiting Farms, Inc.
365 F.3d 1199 (Tenth Circuit, 2004)
Bradley v. Val-Mejias
379 F.3d 892 (Tenth Circuit, 2004)
Duncan v. Manager, Department of Safety
397 F.3d 1300 (Tenth Circuit, 2005)
Minter v. Prime Equipment Co.
451 F.3d 1196 (Tenth Circuit, 2006)
Timmerman v. U.S. Bank, N.A.
483 F.3d 1106 (Tenth Circuit, 2007)
Robinson v. Dean Foods Co.
654 F. Supp. 2d 1268 (D. Colorado, 2009)

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Bluebook (online)
Nelson v. Harris United, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nelson-v-harris-united-llc-oknd-2023.