United States v. Flowers

372 F. Supp. 2d 1319, 2005 WL 1383629
CourtDistrict Court, M.D. Alabama
DecidedMay 20, 2005
DocketCivil Action 2:68cv2709-T
StatusPublished
Cited by3 cases

This text of 372 F. Supp. 2d 1319 (United States v. Flowers) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Flowers, 372 F. Supp. 2d 1319, 2005 WL 1383629 (M.D. Ala. 2005).

Opinion

ORDER

MYRON H. THOMPSON, District Judge.

This litigation, United States v. Flowers, civil action no. 2:68cv2709-T (previously styled United States v. Frazer, and still frequently known today as “Frazer” or the “Frazer litigation”), is before the court on the difficult issue of what discovery, if any, the court should allow before it decides whether Frazer’s 35-year-old “no-bypass rule” should be terminated.

I.

Paragraph 3 of § II of the 1970 injunction in Frazer provides as follows:

“Defendants shall not appoint or offer a position to a lower-ranking white applicant on a certificate in preference to a higher-ranking available Negro applicant, unless the defendants have first contacted and interviewed the higher-ranking Negro applicant and have determined that the Negro applicant cannot perform the functions of the position, is otherwise unfit for it, or is unavailable. In every instance where a determination is made that the Negro applicant is unfit or unavailable, documentary evidence shall be maintained by the defendants that will sustain that finding.”

United States v. Frazer, 317 F.Supp. 1079, 1091 (M.D.Ala.1970). This provision, which embodies what is now called the no-bypass rule, prohibits Alabama state officials from bypassing a higher-ranked African-Ameri *1323 can applicant in favor of a lower-ranked white applicant on a certificate of eligibles. The rule was imposed in response to evidence that, up until 1970, the State of Alabama was unabashedly refusing to hire and promote African-Americans to almost any and all non-menial positions in state government because of their race.

On May 20, 2003, plaintiff United States of America was joined by the defendants, who are officials of the State of Alabama, in filing a motion to terminate the no-bypass rule. This court granted permissive intervention to representatives of African-American employees of the State of the State of Alabama, and to Timothy Pope, a white employee of the Alabama Department of Corrections who says he was denied a promotion because of the no-bypass rule. On January 28, 2004, Pope joined the United States and the state defendants in their termination motion.

This court instructed the parties to agree on a discovery plan, but they could not do so. The United States, the state defendants, and Pope argued that discovery should be limited to an analysis of the data underlying the statistical report that the original parties had submitted, which purports to show that the no-bypass rule is no longer necessary. The African-American intervenors wanted discovery to be much broader, encompassing information about specific instances of alleged discrimination across the State government; they argued that the question of whether the no-bypass rule was still necessary could require an agency-by-agency or classification-by-classification analysis.

This court initially approved the more limited proposed discovery plan of the United States, the defendants, and Pope. However, the court left open the possibility that it would allow more discovery after reviewing the African-American interve-nors’ rebuttal report.

II.

The discovery dispute presented to the court is difficult because the court is confronted with two serious and competing concerns. On the one hand, the court is very reluctant to foreclose further discovery by the African-American intervenors, for the court would be essentially ruling on the merits of the issue presented without having given all interested parties an opportunity to develop their case. Further discovery and court action is warranted on, at least, the important issues presented pursuant to Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579, 113 S.Ct. 2786, 125 L.Ed.2d 469 (1993).

On the other hand, the court is confronted with the following reality: First, the no-bypass rule is a race-conscious provision and, as such, must meet “strict scrutiny” standards and must be “narrowly tailored,” Adarand Constructors, Inc. v. Pena, 515 U.S. 200, 115 S.Ct. 2097, 132 L.Ed.2d 158 (1995); if logic and common sense are to apply, the no-bypass rule cannot be both narrowly tailored and everlasting. Second, the rule has been in effect for approximately 35 years without an independent court review to determine if it continues to meet legal requirements. Because the rule cannot be everlasting, this circumstance is impermissible; in other words, the rule simply cannot continue without a court finding that it continues to meet the demanding requirements for race-conscious relief. Third and finally, the evidentiary record submitted by United States and state defendants shows a strong likelihood that, when all is said and done, the rule cannot continue. Although the court recognizes that the African- *1324 American intervenors maintain that Alabama has not progressed enough to warrant the rule’s termination, it cannot be discounted that the racial make-up of Alabama’s government is dramatically different from what it was in 1970, when the no-bypass rule was imposed.

In resolving these competing concerns, the court concludes that if should be guided by the standards developed for issuing a preliminary injunction. Generally, a preliminary injunction should be entered if the movant clearly establishes that (1) there is a substantial likelihood of success on the merits, (2) irreparable injury will be suffered unless the injunction issues, (3) threatened injury to the movant outweighs whatever damage proposed injunction may cause the opposing party, and (4) the injunction, if issued, would not be adverse to the public interest. McDonald’s Corp. v. Robertson, 147 F.3d 1301, 1307 (11th Cir. 1998). “Ordinarily the first factor is most important.” Garcia-Mir v. Meese, 781 F.2d 1450, 1453 (11th Cir.1986). This court believes that, with these standards tailored to the circumstances of this ease, the United States, the state defendants, and Pope have met them.

As indicated above, there is not only a likelihood, but a strong likelihood, that the United States, the state defendants, and Pope will prevail on the merits of their motions. In light of the substantial positive change in the racial makeup of the government of the State of Alabama after the uninterrupted implementation of the no-bypass rule for 35 years, the court believes that the record strongly suggests that, on balance, the African-American intervenors will not suffer substantial harm from the mere temporary cessation of the no-bypass rule pending the resolution of the pending substantive motions.

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Related

United States v. Flowers
444 F. Supp. 2d 1192 (M.D. Alabama, 2006)
Rogers v. Haley
421 F. Supp. 2d 1361 (M.D. Alabama, 2006)

Cite This Page — Counsel Stack

Bluebook (online)
372 F. Supp. 2d 1319, 2005 WL 1383629, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-flowers-almd-2005.