Russell W. King v. Southwire Company, LLC

District Court, M.D. North Carolina·Decided August 14, 2026·No. 1:24-cv-00664·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA

RUSSELL W. KING, ) ) Plaintiff, ) ) v. ) 1:24-cv-664 ) SOUTHWIRE COMPANY, LLC, ) ) Defendant. )

MEMORANDUM OPINION AND ORDER OSTEEN, JR., District Judge This matter is before this court on Defendant’s Motion for Summary Judgment. (Docs. 19, 20.) Plaintiff filed a response, (Docs. 24, 25), and Defendant filed a reply, (Doc. 28). Oral argument on the motion was held on July 27, 2026. (Docket Entry 07/27/2026.) For the reasons stated herein, Defendant’s motion will be granted. I. BACKGROUND Following oral argument, Plaintiff filed a Motion for Leave to Supplement the Summary Judgment Record. (Doc. 45.) Plaintiff also filed a memorandum in support of the motion, (Doc. 46), a copy of his EEOC Online Inquiry Detail, (Doc. 46–1), and a supplemental affidavit, (Doc. 46–2). Plaintiff seeks to submit “this single EEOC document and supporting affidavit so that Defendant’s dispositive motion may be decided on the most complete factual record available.” (Doc. 46 at 2.)1 Plaintiff contends that the additional information “bears directly on Defendant’s arguments regarding timeliness and equitable tolling” and supports “his efforts to timely pursue administrative relief.” (Id. at 10.) While Defendant has not responded to Plaintiff’s motion, in light of this court’s discussion below, the motion is ready for a ruling. This court finds, first, that Plaintiff’s affidavit and information are not new and not timely. While Plaintiff arguably

should not be permitted to supplement the record with new information because he fails to satisfy this standard, this court nevertheless recognizes the preference within the Fourth Circuit for resolution of cases on the merits, particularly where the denial would be for untimeliness. As a result, this court will consider the affidavit and new information. With respect to the merits of Defendant’s motion for summary judgment, (Doc. 19), this court finds Plaintiff failed to exhaust his administrative remedies by timely filing a charge of discrimination with the EEOC, and that Plaintiff has not carried his burden to prove that the limitations period should be equitably tolled. As a result, Plaintiff’s First Cause of

1 All citations in this Order to documents filed with the court refer to the page numbers located at the bottom right-hand corner of the documents as they appear on CM/ECF. Action, alleging a violation of the Americans with Disabilities Act (“ADA”), 42 U.S.C. § 12112(a), will be dismissed with prejudice. Additionally, Plaintiff’s remaining causes of action for unpaid wages under the North Carolina Wage and Hour Act and common law breach of contract, (Doc. 1 at 9–11), will be dismissed with prejudice. II. ANALYSIS A. Motion to Supplement the Record (Doc. 45) Plaintiff contends this court should allow supplementation

of the record through Plaintiff’s affidavit and the EEOC Online Inquiry Detail because “Plaintiff does not seek to reopen discovery, amend the pleadings, or inject new issues in this litigation” and the information was “reasonably believed unavailable, later discovered, and brought to the Court’s attention.” (Doc. 46 at 8.) The court begins its analysis with Rule 56(e), which provides: If a party fails to properly support an assertion of fact or fails to properly address another party’s assertion of fact as required by Rule 56(c), the court may: (1) give an opportunity to properly support or address the fact; (2) consider the fact undisputed for purposes of the motion; (3) grant summary judgment if the motion and supporting materials — including the facts considered undisputed — show that the movant is entitled to it; or (4) issue any other appropriate order. Fed. R. Civ. P. 56(e). This rule “allows the trial court in its discretion to receive supplemental material in support of or in opposition to a motion for summary judgment before ruling on the motion.” Adardour v. Am. Settlements Inc., 08CV798, 2009 WL 2242635, at *2 (E.D. Va. July 24, 2009) (emphasis and internal quotation marks omitted) (quoting RGI, Inc. v. Unified Indus., Inc., 963 F.2d 658, 662 (4th Cir. 1992)). Courts have recognized that “[t]here appears to be no controlling decision on the propriety of allowing a party to supplement the evidence in support of . . . a motion for summary judgment after it has become ripe for review.” Matheny v. L.E. Myers Co., 16-CV-09304, 2018 WL 1095583, at *1 (S.D.W. Va. Feb. 26, 2018). After reviewing federal court decision on this issue, the court in Matheny identified three instances where supplementation was appropriate, including “when new material is not merely cumulative or corroborative of evidence already in the record, and . . . creates a new question of material fact

that may impact the ruling,” when “doing so provides the court with ‘newly discovered evidence that, with reasonable diligence, could not have been discovered earlier,’” or when “the request is not made in bad faith and will not result in prejudice to the other parties.” Id. (citations omitted) (collecting cases). Here, this court finds that none of the three standards are satisfied. Starting with the first two standards, Plaintiff did not submit the EEOC Online Inquiry Detail as part of the summary judgment briefing, in violation of Rule 6 of the Federal Rules of Civil Procedure. That rule requires that “any opposing affidavit must be served at least 7 days before the hearing.” Fed. R. Civ. P. 6(c)(2). Relatedly, Local Rule 56.1 for the

Middle District of North Carolina requires that a party opposing summary judgment must within “30 days after service of the summary judgment motion and brief, file with the Court a response that . . . sets out the elements that it must prove (with citations to supporting authority), and the specific, authenticated facts existing in the record or set forth in accompanying affidavits.” LR 56.1(e). Under this authority, the supplemental affidavit and records were not timely filed. While Plaintiff’s failure to timely file the EEOC Online Inquiry Detail may not have been a “strategic decision to withhold evidence or an attempt to reopen the record after an adverse ruling,” his actions do not reflect a “prompt effort[]

to ensure that the Court has before it a complete administrative record.” (Doc. 46 at 9.) Regardless of whether or not the EEOC provided the Online Inquiry Detail to Plaintiff through a Freedom of Information Act request, (id.), Plaintiff’s affidavit makes it clear he reviewed his “electronic and paper records relating to [his] EEOC charge,” after the oral argument on Defendant’s motion for summary judgment, (Doc. 46–2 at 1). Because the evidence could have been discovered earlier and is neither new nor timely, this court finds that supplementation is not appropriate under the first two standards articulated above. This court also finds that Plaintiff fails to satisfy the

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