Piatt v. Dolgencorp, LLC

CourtDistrict Court, N.D. Mississippi
DecidedSeptember 5, 2023
Docket3:18-cv-00275
StatusUnknown

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

Bluebook
Piatt v. Dolgencorp, LLC, (N.D. Miss. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF MISSISSIPPI OXFORD DIVISION

CARLEE RYAN PIATT PLAINTIFF

VS. CIVIL ACTION NO: 3:18-cv-00275-MPM-RP

DOLGENCORP, LLC DEFENDANT

ORDER

This cause comes before the court on the motion of defendant Dolgencorp, LLC d/b/a Dollar General, for summary judgment, pursuant to Fed. R. Civ. P. 56. Plaintiff Carlee Ryan Platt has responded in opposition to the motion, and the court, having considered the memoranda and submissions of the parties, is prepared to rule. This is a Title VII sexual harassment case which presents one of the most dramatic differences between the factual account of the plaintiff and that of the defendant, of any case which this court has encountered. In her brief, plaintiff Piatt provides an account of severe sexual harassment which she allegedly suffered at the hands of her former Dollar General Supervisor Dakota Byrd which, if believed by a jury in full, likely constitutes a “slam dunk” Title VII hostile work environment claim. Indeed, plaintiff’s account of sexual harassment includes allegations of an actual rape by Byrd, alleges corporate indifference by Dollar General when it learned of Byrd’s actions, and generally “checks all the boxes” of a Title VII hostile work environment claim. For its part, however, defendant Dollar General responds with a very powerful brief which makes a forceful case that plaintiff’s sexual harassment claims appear to be so powerful precisely because she is fabricating them out of whole cloth, in an attempt to secure a large recovery in this lawsuit. This court notes that there is one limited extent to which the parties’ factual accounts of this case converge, namely in that they each acknowledge that there was a sexual relationship between plaintiff and Byrd during the time she worked at Dollar General. From reading the parties’ briefing, it seems clear that the primary factual dispute between them involves the question of whether Byrd’s advances were “welcome” to plaintiff or not. This is a crucial

question in this case, since the Fifth Circuit has made clear that Title VII only prohibits “requests for sexual favors, and other verbal or physical conduct of a sexual nature that is unwelcome in the sense that it is unsolicited or unincited and is undesirable or offensive to the employee." Marquez v. Voicestream Wireless Corp., 115 F. App'x 699, 701 (5th Cir. 2004)(quoting Wyerick v. Bayou Steel Corp., 887 F.2d 1271, 1274 (5th Cir. 1989)). While this court thus emphasizes that defendant only faces potential legal liability for sexual advances by Byrd which were “unwelcome” to plaintiff, it must state for the record that, even under defendant’s version of the facts, Byrd engaged in conduct which must be regarded as highly ill-advised and inappropriate. Indeed, it seems clear that Dollar General could have

avoided any threat of legal liability in this case if it had, through its hiring or training practices, managed to avoid employing a store manager who deemed it appropriate to start a sexual relationship with an employee under his supervision. It is, with good reason, widely accepted in today’s society that this is a practice which is, under the best of circumstances, exceedingly unwise and which almost inevitably leads to negative consequences. It is nevertheless undisputed that Dollar General hired a manager who engaged in such conduct, and it therefore seems clear that, even under its version of the facts, defendant is far from “squeaky clean” in this matter. That brings this court to the crucial fact, which is ultimately dispositive of the present motion, that it must “view the [summary judgment] facts in the light most favorable to the plaintiff,” as the non-moving party. Wilkerson v. Goodwin, 774 F.3d 845, 851 (5th Cir. 2014). Stated differently, this court is not serving as a neutral arbiter of the facts at this stage of the proceedings. To the contrary, this court has the legal obligation, at this juncture, to place its

thumb on the scale in favor of the plaintiff in its consideration of the factual issues in this case. In light of this obligation, this court is simply not in a position to do what defendant would have it do, namely reject out of hand plaintiff’s lengthy sworn deposition testimony in which she provides a detailed account of severe sexual harassment which she claims to have suffered at the hands of Byrd. This court further notes that, since it is an established fact that Byrd is the sort of manager who is willing to engage in a sexual affair with an employee under his supervision, it is not a great factual leap for jurors to conclude that he is also the sort of manager who is so driven by his sexual urges that he would continue to pursue an employee even after she had expressed some

degree of initial resistance to his advances. In so stating, this court observes that not all consensual sex acts involve an instant agreement by the target of the seduction to engage in sex. Rather, there is often an element of pursuit and persuasion involved and the overcoming of initial resistance. This court submits that while the overcoming of any such initial resistance will likely suffice to remove the possibility of criminal liability, it is very much an open question whether it would suffice to render the encounter “welcome” as a matter of law within the meaning of Title VII. Indeed, this court believes that, in the context of an already highly inappropriate attempted seduction of an employee by a manager, any initial resistance by the employee should suffice to render the advance “unwelcome” within the meaning of Title VII, or at the very least to create triable jury issues in this regard. In this vein, this court notes that, judging by the parties’ briefing, neither the Fifth Circuit nor the U.S. Supreme Court appear to have provided clear guidelines on what is or is not an “unwelcome” sexual advance in this context, which makes this court even more inclined to submit these issues to a jury. This court further observes that it is entirely possible for two things to be true at once.

That is, it is entirely possible for Byrd to have made an “unwelcome” sexual advance upon plaintiff, and yet for her to have ultimately given in to his advances and engaged in a relationship with him which, at some point, became consensual. It is further possible for plaintiff to have an entirely valid Title VII claim in this case and yet for her to have lied in her deposition by providing an exaggerated depiction of Byrd’s actions in order to increase her potential financial recovery. In this court’s experience, the truth in matters such as these often involves “shades of grey,” and it frankly appears from the record that neither of the principals of the sexual affair in this case are saintly individuals. Naturally, jurors will be under no obligation to accept either side’s version of the events in full, but it seems clear from the record that they will be the ones to

make the ultimate factual findings in this case. Having previewed its ultimate summary judgment ruling in this case, this court now discusses the factual allegations set forth in plaintiff’s brief. In providing her version of events, plaintiff begins by implying that it was Byrd’s intent to pursue her even before she began working at Dollar General. Indeed, plaintiff alleges that Byrd suggested that she apply for a position with the store after seeing her Facebook page.

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Related

Marquez v. Voicestream Wireless Corp.
115 F. App'x 699 (Fifth Circuit, 2004)
Joyce Wyerick v. Bayou Steel Corporation
887 F.2d 1271 (Fifth Circuit, 1989)
Robert Wilkerson v. Richard Stalder
774 F.3d 845 (Fifth Circuit, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
Piatt v. Dolgencorp, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/piatt-v-dolgencorp-llc-msnd-2023.