Paige v. Metropolitan Security Services, Inc., d/b/a Walden Security

District Court, S.D. Mississippi·Decided July 6, 2020·No. 3:18-cv-00765·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI NORTHERN DIVISION

JAMES PAIGE, JR. PLAINTIFF

V. CIVIL ACTION NO. 3:18-CV-765-SA-RP

METROPOLITAN SECURITY SERVICES, d/b/a WALDEN SECURITY et al DEFENDANTS

ORDER AND MEMORANDUM OPINION On June 10, 2020, this Court entered an Order and Memorandum Opinion [94] granting summary judgment in favor of Metropolitan Security Services and dismissing all of the Plaintiff’s claims against it. In addition, the Court identified three material facts that may not be genuinely in dispute and ordered the remaining parties to submit briefing on whether the Court should grant summary judgment and dismiss all of the Plaintiff’s claims. After giving each party 14 days to respond as required by Rule 56(f)(3) of the Federal Rules of Civil Procedure, the Court is now prepared to rule. Factual and Procedural History1 This dispute arose after James Paige, a career Court Security Officer at the Federal Courthouse in Jackson, Mississippi, was not hired as the new district manager. Paige applied for the position within the posted application window but after Walden Security had already filled the position. Paige claimed that he was discriminated against because of his race when he was passed over for the position. Paige filed his Complaint [1] on November 1, 2018, against Walden Security, Attorney General William Barr, and the United States Department of Justice alleging race discrimination

1 A more in-depth factual recitation can be found in the Court’s Order and Memorandum Opinion [94]. under Title VII of the Civil Rights Act of 1964. Paige later amended his Complaint [34] to add Gaylen Knupp and Brandon Pritchard, in their individual and official capacities, as defendants. In addition, Paige added a Section 1981 claim against all defendants. Walden Security filed a Motion for Summary Judgment [69] seeking dismissal of the Plaintiff’s race discrimination claim against it. This Court granted that motion and dismissed

Walden Security as a defendant. See [94]. In its Order and Memorandum Opinion, the Court notified the remaining parties that it intended to consider summary judgment on the remaining claims and gave the parties 14 days to file a response. Only the United States and the Plaintiff filed timely responses to the Court’s Order [94]. The issues are now ripe for review. Legal Standard The Court may “consider summary judgment on its own after identifying for the parties material facts that may not be genuinely in dispute.” Fed. R. Civ. P. 56(f)(3). A court may grant summary judgment under rule 56(f)(3) so long as it provides the parties with “ample notice [and] time to respond” and “consider[s] everything” that the parties claim to be probative of the matters

that have been identified. Santana v. Cook Co. Bd. of Review, 679 F.3d 614, 619 (7th Cir. 2012); see also Wang v. Prudential Ins. Co. of Am., 439 Fed. Appx. 359, 363 n.2 (5th Cir. 2011). Summary judgment is warranted when the evidence reveals no genuine dispute regarding any material fact, and the moving party is entitled to judgment as a matter of law. FED. R. CIV. P. 56(a). The rule “mandates the entry of summary judgment, after adequate time for discovery and upon motion, against a party who fails to make a showing sufficient to establish the existence of an element essential to that party’s case, and on which that party will bear the burden of proof at trial.” Celotex Corp. v. Catrett, 477 U.S. 317, 322, 106 S. Ct. 2548, 91 L. Ed. 2d 265 (1986). The moving party “bears the initial responsibility of informing the district court of the basis for its motion and identifying those portions of [the record] which it believes demonstrate the absence of a genuine issue of material fact.” Id. at 323, 106 S. Ct. 2548. The nonmoving party must then “go beyond the pleadings” and “designate ‘specific facts showing that there is a genuine issue for trial.’” Id. at 324, 106 S. Ct. 2548 (citation omitted). In reviewing the evidence, factual

controversies are to be resolved in favor of the non-movant, “but only when both parties have submitted evidence of contradictory facts.” Little v. Liquid Air Corp., 37 F.3d 1069, 1075 (5th Cir. 1994) (en banc). When such contradictory facts exist, the Court may “not make credibility determinations or weigh the evidence.” Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 150, 120 S. Ct. 2097, 147 L. Ed. 2d 105 (2000). Conclusory allegations, speculation, unsubstantiated assertions, and legalistic arguments are not an adequate substitute for specific facts showing a genuine issue for trial. TIG Ins. Co. v. Sedgwick James of Wash., 276 F.3d 754, 759 (5th Cir. 2002); SEC v. Recile, 10 F.3d 1093, 1097 (5th Cir. 1997); Little, 37 F.3d at 1075. Discussion

In its Order and Memorandum Opinion [94], the Court identified the following three legal issues on which it intends to consider summary judgment: (1) the Plaintiff’s Title VII and Section 1981 claims against the U.S. Marshal Service through the Attorney General and the United States; (2) the Plaintiff’s Title VII and Section 1981 claims against Gaylen Knupp in his individual and official capacities; and (3) the Plaintiff’s Title VII and Section 1981 claims against Brandon Pritchard in his individual and official capacities. First, the Plaintiff claims that the U.S. Marshal Service is a joint-employer and is liable for race discrimination in violation of Title VII and Section 1981.2 As the Court explained in its prior Opinion [94], the joint-employer doctrine is not applicable to governmental subdivisions. See Trevino v. Celanese Corp., 701 F.2d 397, 404 n.10 (5th Cir. 1983); see also Crain v. Metropolitan Security Services, Inc., 3:17-cv-868-SA Docket [55]. Thus, because the U.S. Marshal Service is a

governmental subdivision, it cannot be considered a “joint-employer.” Absent “employer” status, the Marshal Service is not subject to liability under Title VII of the Civil Rights Act.3 In addition, the Plaintiff alleged that the U.S. Marshal Service violated Section 1981. “To prevail [on a section 1981 claim], a plaintiff must initially plead and ultimately prove that, but for race, [he] would not have suffered the loss of a legally protected right.” Comcast Corporation v. National Association of African American-Owned Media, 140 S.Ct. 1009, 1019, 296 L. Ed. 2d 356 (2020). The Court previously found that no genuine dispute of material fact existed as to whether Walden Security discriminated against Paige on the basis of his race. Without additional facts suggesting that the U.S. Marshal Service had any involvement in the promotion process or

discriminated against him in the process, Paige cannot establish the existence of a genuine issue of material fact that he was discriminated against. Therefore, the Court finds that summary judgment is proper on the Plaintiff’s claims against the U.S. Marshal Service, the United States, and the Attorney General of the United States.4

2 The Plaintiff conceded in his additional briefing that there are no genuine disputes of material facts as to whether the U.S.

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Paige v. Metropolitan Security Services, Inc., d/b/a Walden Security, (S.D. Miss. 2020).

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