Pellant v. Detroit Tigers, Inc.

CourtDistrict Court, E.D. Michigan
DecidedJanuary 13, 2025
Docket2:23-cv-13288
StatusUnknown

This text of Pellant v. Detroit Tigers, Inc. (Pellant v. Detroit Tigers, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pellant v. Detroit Tigers, Inc., (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION GARY PELLANT and RANDALL JOHNSON,

Plaintiffs, Case No. 2:23-cv-13288 Hon. Brandy R. McMillion v.

DETROIT TIGERS, INC.,

Defendant. _________________________________/ OPINION AND ORDER GRANTING IN PART AND DENYING IN PART DEFENDANT’S MOTION TO DISMISS (ECF NO. 6), STAYING THE CASE, AND CLOSING CASE ADMINISTRATIVELY

Before the Court is Defendant Detroit Tigers, Inc.’s (“the Tigers”) Motion to Dismiss (ECF No. 6). For the reasons below, the Court will GRANT IN PART AND DENY IN PART the Tigers’ Motion to Dismiss (ECF No. 6), STAY the case pending resolution of the earlier filed litigation now pending in the United States District Court for the Southern District of New York, and CLOSE THE CASE ADMINISTRATIVELY. I. This case concerns alleged age discrimination against professional baseball scouts. A few initial matters bear mentioning. First, there are three cases that are relevant to this Motion: (1) D. Colo. Case No. 23-cv-01563 (“the Colorado case”); (2) this case, E.D. Mich. Case No. 23-cv-13288 (“the Michigan case”); and (3) S.D.N.Y. Case No. 24-cv-04314 (“the New York case”). The Colorado case was

transferred to the Southern District of New York and became the New York case.1 Next, it is important to understand the “first-to-file” rule. That rule says that when two actions involving similar parties and issues are filed in two separate

district courts, the case filed first should generally be the one to proceed. Baatz v. Columbia Gas Transmission, LLC, 814 F.3d 785, 789 (6th Cir. 2016). Three factors govern application of the first-to-file rule: (1) which complaint was filed first, (2) the similarity of the parties, and (3) the similarity of the issues and claims. Id.

Equitable considerations are also relevant, even if all three factors support applying the rule. Id. Here, the Colorado case (eventually transferred to New York) was filed before the Michigan case.

Additionally, it is worth explaining how scouting works in baseball. Major League Baseball (“MLB” or “the League”) teams hire scouts through an informal process. D. Colo. Case No. 23-cv-01563, ECF No. 1, PageID.16-17. If a team is interested in hiring a scout, they typically (and informally) reach out to the scout.

Id. There are no formal job postings or advertisements, so getting a job as a scout is

1 The complaint in the New York case is largely the same as the complaint in the Colorado case, minus the various state-law claims initially raised in the Colorado case. At times, the Court will refer to the class action filed in Colorado and transferred to New York as the “Colorado-New York case.” “about networking” and attending “formal and informal meetings” like MLB annual meetings. Id. Baseball scouts “evaluate players’ skills” and do so across the world

and at all levels of the game—high school, college, international, minor league, and major league. See E.D. Mich. Case No. 23-cv-13288, ECF No. 1, PageID.4. Many scouts—including the older scouts here—use statistical analysis to evaluate players.

See D. Colo. Case No. 23-cv-01563, ECF No. 1, PageID.23. But teams are increasingly relying on “analytics” and video scouting to complete these evaluations. Id. at PageID.13. Scouts evaluate players on a scale and present their evaluations to the teams in reports. See E.D. Mich. Case No. 23-cv-13288, ECF No. 1, PageID.5;

D. Colo. Case No. 23-cv-01563, ECF No. 1, PageID.14. Notably, scouts do not make personnel decisions—those decisions are reserved for the “front office” staff of each MLB team. D. Colo. Case No. 23-cv-01563, ECF No. 1, PageID.14.

A. The Colorado Complaint On June 21, 2023, 17 former MLB scouts (over the age of 40 who worked for one or more of the 30 MLB teams) filed a collective class action complaint in the United States District Court for the District of Colorado. D. Colo. Case No. 23-cv-

01563, ECF No. 1, PageID.2.2 They alleged in their initial complaint that the teams denied them reemployment based on their age, in violation of the Age

2 Included in those 17 plaintiffs was currently named Plaintiff Randall Johnson. As will be explained in more detail later, Plaintiff Gary Pellant was not added as a plaintiff until a later amended complaint was filed. Discrimination in Employment Act (“ADEA”), 29 U.S.C. § 621 et seq. as well as various state law discrimination statutes. See generally D. Colo. Case No. 23-cv-

01563, ECF No. 1. The Colorado plaintiffs were among “thousands of MLB and Club employees separated from employment” with the defendant teams in the last eight years after

the MLB and the individual teams decided to replace older employees with younger ones. D. Colo. Case No. 23-cv-01563, ECF No.1, PageID.13. The new MLB commissioner, Robert Manfred (“the Commissioner”), wanted scouts to focus more on “analytics” and “video scouting.” Id. This, the plaintiffs alleged, led the MLB

to “heavily recruit[]” younger scouts and simultaneously and “intentionally push[] out” the older ones. Id. The MLB based its decision, the plaintiffs say, on a “false stereotype” that older scouts “lacked the ability” to use analytics and video scouting

with the same skill level as younger scouts. Id. Alleging that the League and teams have “coordinated their behavior” and “implemented a pattern, practice and de facto rule,” the Colorado plaintiffs claimed that the defendants applied rules to the scouts that were only applicable to players,

coaches, managers, and umpires. D. Colo. Case No. 23-cv-01563, ECF No. 1, PageID.15-16. They applied those rules to “prohibit[] communication about job opportunities while a Scout is under contract with a Club.” Id. The plaintiffs

claimed this practice was anti-competitive, “inhibit[ed] lateral hiring,” and “restrain[ed] the Scout labor market.” Id. at PageID.16. It had the effect of rendering a scout “stuck with his or her Club employer until the Club terminate[d] the Scout.”

Id. at PageID.17. The Colorado plaintiffs alleged that in 2020, 2021, and 2022, the age discrimination presented in several ways. First, the defendants applied “Rule

3(k)”—a rule thought to only prohibit employment-related discussions between teams and players, coaches, managers, or umpires employed by other teams—to scouts to either decline to renew their contracts or terminate them. D. Colo. Case No. 23-cv-01563, ECF No. 1, PageID.17. Second, the League and teams

“prevent[ed] the reemployment of Older Scouts” or refused to reemploy them. Id. According to the Colorado plaintiffs, the teams maintained a list of “Senior Scouts formerly associated with one or more Clubs” and “used [it] to refuse to rehire” those

scouts. Id. at PageID.21. Additionally, directives from the Commissioner’s office “frustrat[ed] or otherwise prevent[ed] the rehiring” of scouts. Id. And last, teams maintained a list of older scouts “who cannot be hired back into professional baseball” because of their age; and certain plaintiffs were told by teams that they

could not apply for new jobs “based on such a list.” Id. The Colorado plaintiffs raise two forms of pretext for firing older scouts: (1) the COVID-19 pandemic and (2) the rising use of analytics in scouting. D. Colo.

Case No. 23-cv-01563, ECF No. 1, PageID.22-23. Of the 83 older scouts, the teams “did not renew or otherwise terminate[d]” the contract for 51 of them. Id. at PageID.22. Those older scouts affected were told their terminations “related to the

COVID-19 pandemic.” Id. at PageID.23.

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