U.S. Equal Employment Opportunity Commission v. Discount Auto Parts LLC

CourtDistrict Court, S.D. Florida
DecidedMay 22, 2025
Docket9:24-cv-81200
StatusUnknown

This text of U.S. Equal Employment Opportunity Commission v. Discount Auto Parts LLC (U.S. Equal Employment Opportunity Commission v. Discount Auto Parts LLC) is published on Counsel Stack Legal Research, covering District Court, S.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
U.S. Equal Employment Opportunity Commission v. Discount Auto Parts LLC, (S.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO. 24-CV-81200-ROSENBERG

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,

Plaintiff,

v.

DISCOUNT AUTO PARTS LLC & ADVANCE AUTO PARTS, INC.,

Defendants. ________________________________________/

ORDER GRANTING MOTION TO INTERVENE AND ADD NEW CLAIMS AND EXTENDING REMAINING DEADLINES

THIS MATTER is before the Court on Prospective Intervenor Jessica Warrens’ Motion for Leave to Intervene (the “Motion”) [DE 38]. Defendant Discount Auto Parts, LLC filed a Partial Opposition to the Motion [DE 39]. The Court has reviewed the Motion, Defendant’s partial opposition, Warrens’ Reply in support of the Motion [DE 40], and the record. For the reasons discussed below, the Motion is GRANTED. On September 30, 2024, the Equal Employment Opportunity Commission (the “EEOC”) initiated this action against Defendant Discount Auto Parts.1 DE 1. The Complaint alleged that Defendant discriminated against its employees on the basis of both their race and sex by creating a hostile work environment. Id. ¶ 59, 63, 67. The EEOC brought its claims specifically on behalf of Jessica Warrens and generally on behalf of other LGBTQ employees and Black employees. Id.

1 Although the EEOC also initially sued Advanced Auto Parts, Inc., the parties jointly stipulated to dismiss Advanced Auto Parts, Inc. from the suit. DE 42. As a result, DAP is the only remaining defendant. On December 9, 2024, Defendant moved to dismiss the Complaint. DE 11. Then, on February 27, 2025, the Court denied that motion. DE 34. Defendant filed its Answer on March 7, 2025. DE 35. Less than three weeks later, Jessica Warrens filed her Motion to Intervene as a plaintiff. DE 38. Defendant opposes Warrens’ Motion in part, DE 39, but the EEOC does not oppose Warrens’

intervention, DE 38 at 3. The Motion requests leave to intervene under Federal Rule of Civil Procedure 24. DE 38 at 2. Rule 24(a) allows for intervention as a matter of right and requires that (1) the motion be timely, and (2) the prospective intervenor (a) has a statutory right to intervene, or (b) claims an interest that is subject to the action, is not adequately represented by another party, and would otherwise be impaired if they were not permitted to intervene. The prospective intervenor bears the burden to demonstrate that intervention is appropriate. Burke v. Ocwen Fin. Corp., 833 F. App’x 288, 291 (11th Cir. 2020). Timeliness is determined by considering: (1) the length of time during which the proposed intervenor knew or reasonably should have known of its interest in the case before moving to intervene; (2) the

extent of prejudice to the existing parties as a result of the proposed intervenor’s failure to move for intervention as soon as it knew or reasonably should have known of its interest; (3) the extent of prejudice to the proposed intervenor if its motion is denied; and (4) the existence of unusual circumstances militating either for or against a determination that its motion was timely. Brown ex rel. O’Neil v. Bush, 194 F. App’x 879, 882 (11th Cir. 2006) (alterations adopted); United States v. Jefferson Cnty., 720 F.2d 1511, 1516 (11th Cir. 1983) (“Th[e] [same timeliness] analysis applies whether intervention of right or permissive intervention under [Rule] 24 is claimed.”). However, “timeliness is not a word of exactitude or of precisely measurable dimensions” and it

2 “must have accommodating flexibility toward both the court and the litigants if it is to be successfully employed to regulate intervention in the interest of justice.” Georgia v. U.S. Army Corps of Eng’rs, 302 F.3d 1242, 1260 (11th Cir. 2002) (alterations adopted). Defendant does not oppose Warrens’ request to intervene as a matter of right so long as

she is not permitted to add claims not previously brought by the EEOC. DE 39 at 3. Warrens has a statutory right to intervene pursuant to 42 U.S.C. § 2000e-5(f) which states that the “person or persons aggrieved shall have the right to intervene in a civil action brought by the [EEOC].” See also EEOC v. STME, LLC, 938 F.3d 1305, 1322 (11th Cir. 2019) (“The language of § 2000e- 5(f)(1) unambiguously gives employees an unconditional right to intervene in EEOC enforcement actions.”). Warrens seeks to intervene as a matter of right to maintain the EEOC claims in her own capacity and to assert new claims for retaliation under Title VII and for violations of the Florida Civil Rights Act (“FCRA”). DE 38 at 2. To that end, Defendant argues that adding the new claims is untimely under Rule 24(a). The Court finds the request to intervene under Rule 24(a) is appropriate because the second, third, and fourth timeliness factors weigh in favor of

allowing Warrens to intervene. The first timeliness factor weighs against Warrens. As Defendant argues, Warrens filed her Motion six months after the EEOC initiated the Complaint against Defendant. Id. at 3. But, as the action was brought on her behalf, Warrens should have reasonably known of her interest in intervening at that point. But see Jefferson Cnty., 720 F.2d at 1516 (“[M]ere knowledge of the pendency of an action, without appreciation of the potential adverse effect an adjudication of that action might have on one’s interests, does not preclude intervention.”). The remaining timeliness factors weigh in Warrens favor. Defendant argues that the second factor—the prejudice the existing parties will face if Warrens is allowed to intervene—

3 weighs in its favor. Specifically, Defendant argues that the addition of new claims is untimely as it comes after the Court’s established deadline to do so—March 21, 2025. Id. (citing the Court’s Scheduling Order at DE 27). Defendant argues that it has engaged “in a significant amount of fact discovery” with the EEOC, including the production of documents and conference on responses

and objections to discovery requests, without the benefit of the proposed additional claims. Defendant contends that the focus of discovery has been on “claims of harassment and do not address issues concerning retaliation, disciplinary action, discharge, and back pay damages.” Id. at 3–4. Moreover, allowing for the addition of the claims will require that Defendant “revisit written discovery requests and responses to address the new allegations and claimed damages, which are separate from the EEOC.” Id. at 4. Defendant is concerned that it will be prejudiced as the discovery cutoff date is on August 1, 2025, which is less than four months from the date of Warrens’ motion. Id. The Court maintains case management discretion to extend deadlines. Thus, to extent that Defendant would be prejudiced by the addition of the new claims, the Court may extend the

remaining deadlines if needed, even though Warrens did not assert any new facts in her prospective intervenor complaint but reasserted and relied upon the facts as alleged by the EEOC. See DE 38- 1; DE 1. Although the Title VII retaliation claim has substantively different elements from the EEOC’s alleged Title VII claims, the claims arise from the same set of facts. Much of the discovery produced in relation to the Title VII claims brought by the EEOC will be applicable to Warrens’ FCRA claims. The “FCRA is modeled after Title VII, and claims brought under it are analyzed under the same framework, . . . and their outcome is the same as the federal ones.” Alvarez v.

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Related

Brown Ex Rel. O'Neil v. Bush
194 F. App'x 879 (Eleventh Circuit, 2006)
Georgia v. United States Army Corps of Engineers
302 F.3d 1242 (Eleventh Circuit, 2002)
Alvarez v. Royal Atlantic Developers, Inc.
610 F.3d 1253 (Eleventh Circuit, 2010)
United States v. Jefferson County
720 F.2d 1511 (Eleventh Circuit, 1983)

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U.S. Equal Employment Opportunity Commission v. Discount Auto Parts LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/us-equal-employment-opportunity-commission-v-discount-auto-parts-llc-flsd-2025.