United States v. Electron Hydro LLC

CourtDistrict Court, W.D. Washington
DecidedFebruary 28, 2022
Docket2:20-cv-01746
StatusUnknown

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

Bluebook
United States v. Electron Hydro LLC, (W.D. Wash. 2022).

Opinion

THE HONORABLE JOHN C. COUGHENOUR 1 2 3 4 5 6 UNITED STATES DISTRICT COURT 7 WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE 9 UNITED STATES OF AMERICA, et al., CASE NO. C20-1746-JCC 10 Plaintiffs, and ORDER 11 PUYALLUP TRIBE OF INDIANS, 12 Plaintiff-Intervenor, 13 v. 14 ELECTRON HYDRO, LLC, 15 Defendant. 16

17 This matter comes before the Court on Plaintiff United States of America’s (“United 18 States”) motion for leave to file an amended complaint (Dkt. No. 51) and Defendant Electron 19 Hydro LLC’s (“Electron Hydro”) motion to stay discovery. (Dkt. No. 46.) Having thoroughly 20 considered the parties’ briefing and the relevant record, the Court hereby GRANTS the United 21 States’ motion for leave to amend (Dkt. No. 51) and DENIES Electron Hydro’s motion to stay 22 (Dkt. No. 46) for the reasons explained below. 23 I. BACKGROUND 24 Electron Hydro operates a hydroelectric facility located on the Puyallup River in Pierce 25 County, Washington. (Dkt. No. 51-2 at 1–2.) In July 2020, as alleged in the United States’ 26 proposed Amended Complaint, Electron Hydro started reconstructing the facility’s diversion 1 dam structure and spillway. (Id.) Under the supervision of its Chief Operating Officer, Thom A. 2 Fischer, Electron Hydro personnel created a bypass channel lined with waste field turf. (See id. at 3 2.) 4 On or about July 29, 2020, due to a partial breach of a plastic liner, approximately 617 5 square yards of the field turf and four to six cubic yards of crumb rubber discharged into the 6 river, portions of which continue to be found in various locations downstream. (Id. at 13, 14.) On 7 or about October 19, 2020, Electron Hydro then started constructing a diversion rock spillway, 8 discharging approximately 6,000 cubic yards of rock, gravel, and other fill material into the 9 Puyallup River. (Id. at 14.) On November 11, 2020, the United States sued under the Clean 10 Water Act to obtain injunctive relief and civil penalties against Electron Hydro for unauthorized 11 discharges into the Puyallup River. (Dkt. No. 1.) On January 10, 2022, the Washington State 12 Attorney General’s Office filed criminal charges in Pierce County Superior Court against 13 Electron Hydro and Mr. Fischer for, among other things, the unlawful discharge of pollutants 14 into the Puyallup River. (Dkt. Nos. 46 at 2, 48-1, 48-2.) 15 The United States now seeks leave to amend its complaint to, among other things, add 16 Mr. Fischer as a defendant in this action. (See Dkt. No. 51-2 (proposed amended complaint).) 17 Electron Hydro moves to stay all discovery in this matter pending resolution of the state criminal 18 proceedings, arguing that a stay is necessary to preserve Mr. Fischer’s Fifth Amendment 19 privilege against self-incrimination. (See generally Dkt. No. 46.) 20 II. DISCUSSION 21 A. United States’ Motion for Leave to File Amended Complaint 22 The United States moves to amend its complaint to add (1) Mr. Fischer as an individual 23 defendant in this matter; (2) a claim for the unpermitted discharge of fill material under Section 24 404 of the CWA, 33 U.S.C. § 1344; and (3) additional factual allegations supporting its claims. 25 (Id. at 1–2.) Electron Hydro does not oppose this request. (Dkt. No. 68.) Accordingly, the Court 26 finds that justice requires granting leave to amend to the United States under Federal Rule of 1 Civil Procedure 15(a)(2). 2 B. Electron Hydro’s Motion to Stay Discovery 3 The Constitution does not require a stay of civil proceedings pending the outcome of 4 criminal proceedings absent “substantial prejudice to the rights of the parties involved.” Keating 5 v. Office of Thrift Supervision, 45 F.3d 322, 325 (9th Cir. 1995); see also Whitsitt v. Allen & 6 Assocs., LLC, 2014 WL 11997865, slip op. at 2 (W.D. Wash. 2014) (noting that a stay of a civil 7 case pending conclusion of a related criminal case is an “extraordinary remedy”) (internal 8 quotations omitted). To determine whether a stay is appropriate, a court should consider “the 9 extent to which the defendant’s Fifth Amendment rights are implicated.” Keating, 45 F.3d at 10 324. 11 Electron Hydro argues that a stay is appropriate because its civil case relies on the 12 testimony of Mr. Fischer, who would undoubtedly assert his Fifth Amendment privilege against 13 self-incrimination. (Dkt. No. 46 at 5–6.) The United States argues that this fact alone is not 14 determinative, and that less drastic means would be sufficient to protect Mr. Fischer’s Fifth 15 Amendment rights. (Dkt. Nos. 54 at 6–9, 63 at 4.) The Court agrees that less drastic alternatives 16 are available, such as delaying Mr. Fischer’s deposition. Additionally, the Court notes that 17 Electron Hydro fails to demonstrate substantial prejudice in the absence of a stay. 18 Courts have repeatedly emphasized that a defendant has “no absolute right not to be 19 forced to choose between testifying in a civil matter and asserting his Fifth Amendment 20 privilege.” Keating, 45 F.3d at 326. And Electron Hydro itself has no Fifth Amendment rights. 21 Curcio v. United States, 354 U.S. 118, 122 (1957). Nor does Electron Hydro demonstrate an 22 inability to respond to discovery with information that would not incriminate Mr. Fischer. And 23 generalized Fifth Amendment concerns are insufficient to establish substantial prejudice. See, 24 e.g., Federal Sav. and Ins. Corp. v. Molinaro, 889 F.2d 899, 903 (9th Cir. 1989); Commodity 25 Futures Trading Comm’n. v. Fin. Tree, 2021 WL 2681920, slip op. at 3 (W.D. Wash. 2021)). 26 Moreover, although the extent to which Mr. Fischer’s Fifth Amendment privilege is 1 implicated is, indeed, a “significant factor” in determining whether a stay is warranted, it must be 2 weighed against:

3 (1) the interests of the plaintiffs in proceeding expeditiously with this litigation or 4 any particular aspect of it, and the potential prejudice to plaintiffs of a delay; (2) the burden which any particular aspect of the proceedings may impose on 5 defendants; (3) the convenience of the court in the management of its cases, and the efficient use of judicial resources; (4) the interests of persons not parties to the 6 civil litigation; and (5) the interest of the public in the pending civil and criminal litigation. 7 Keating, 45 F.3d at 325. This Court finds that, after consideration of all the factors, the 8 extraordinary remedy of granting a stay is not appropriate. 9 1. Plaintiffs’ Interests 10 Plaintiffs’ interests in proceeding expeditiously and the potential prejudice caused by a 11 delay favors denying the motion to stay. They argue that toxins from the artificial turf remaining 12 in the river are causing ongoing environmental damage. (Dkt. Nos. 54 at 3–4, 6; 59 at 7; 63 at 3– 13 4.) Plaintiffs emphasize that the only available remedies in the state criminal case are jail time 14 and fines, which do not minimize or mitigate these ongoing harms. (Id.) Electron Hydro argues 15 that, even without any court orders in place, it has made an enormous effort to retrieve artificial 16 turf from the river. (Dkt. No. 66 at 1–2.) Regardless, Plaintiffs maintain that the harm caused by 17 Defendant’s conduct has not ceased and that turf, crumb rubber, and other pollutants remain in 18 the river. (Dkt. Nos. 54 at 6, 59 at 7, 63 at 3.) The evidence they provide supporting this 19 contention is compelling. (See Dkt. Nos. 56, 57-1–57-4, 58, 60, 60-1–60-23, 65-1.) 20 Moreover, courts generally find that a plaintiff’s interest is prejudiced when a stay would 21 cause a lengthy or indefinite delay. See, e.g., CommScope, Inc. of North Carolina v.

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Curcio v. United States
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Federal Savings & Loan Insurance v. Molinaro
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United States v. Electron Hydro LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-electron-hydro-llc-wawd-2022.