Welch v. United Network for Organ Sharing

CourtDistrict Court, M.D. Tennessee
DecidedMarch 14, 2025
Docket3:24-cv-00422
StatusUnknown

This text of Welch v. United Network for Organ Sharing (Welch v. United Network for Organ Sharing) is published on Counsel Stack Legal Research, covering District Court, M.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Welch v. United Network for Organ Sharing, (M.D. Tenn. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION

DEXTER WELCH, ) ) Plaintiff, ) ) v. ) No. 3:24-cv-00422 ) UNITED NETWORK FOR ORGAN ) SHARING, et al., ) ) Defendants. )

MEMORANDUM OPINION AND ORDER Before the Court is Dexter Welch’s (“Welch”) Motion for Reconsideration of Order on Summary Judgment. (Doc. No. 120). Welch moves for the Court to reconsider its decision denying Welch’s motion for summary judgment on his Title VI claim against Vanderbilt University Medical Center (“VUMC”), as well as the Court’s decision granting VUMC’s motion for summary judgment on Welch’s breach of fiduciary duty claim. (Doc. No. 120-1). VUMC informed Welch of its intent to oppose. (Doc. No. 120-2 ¶ 2). Because Welch’s motion merely refashions old arguments and boldly introduces new ones at the eleventh hour, the Court did not deem a response from VUMC necessary. M.D. Tenn. L.R. 7.01(a)(3) (“Except for motions for reconsideration (to which no response shall be filed unless ordered by the Court), any party opposing a motion” must file opposition within 14 days after service of the motion.). For the following reasons, Welch’s motion (Doc. No. 120) is GRANTED and having reconsidered, the Court finds no clear error and so there is no basis to modify its decision (Doc. Nos. 118, 119). I. BACKGROUND AND LEGAL STANDARD On February 19, 2025, the Court ruled on various pending motions, including Welch’s Motion for Summary Judgment (Doc. No. 95) and Defendants’ Motion for Summary Judgment (Doc. No. 86). (Doc. Nos. 118, 119). In its ruling, the Court: (1) denied Welch’s Motion (Doc. No. 95) on his Title VI claim against VUMC because of Welch’s improper reliance on the strict scrutiny standard governing racial classification claims; and (2) granted VUMC’s Motion (Doc. No. 86) on Welch’s breach of fiduciary duty claim, given VUMC does not owe Welch a fiduciary

duty as a matter of law, and Welch failed to point to evidence creating a genuine dispute of material fact as to his theory of vicarious liability, which was sparingly pled and only introduced in opposition to VUMC’s Motion. Welch now moves for reconsideration of these decisions pursuant to Federal Rule of Civil Procedure 54(b) and Local Rule 7.01(a), asserting both rulings are clear error. Under Rule 54(b), any order or other decision, however designated, that adjudicates fewer than all the claims or the rights and liabilities of fewer than all [of] the parties does not end the action as to any of the claims or parties and may be revised at any time before the entry of a judgment adjudicating all the claims and all the parties’ rights and liabilities.

The express language of Rule 54(b) does not provide for motions for reconsideration by parties. See Fed. R. Civ. P. 54(b). Nor does it prescribe standards or bases for revisions of challenged decisions. Id. Local Rule 7.01(a) does little to resolve this ambiguity, as it does not provide for the circumstances through which a party may move for reconsideration, nor the applicable standard of review. M.D. Tenn. L.R. 7.01(a). Rather, it refers to motions for reconsideration only within the context of responsive motions, stating: Except for motions for reconsideration (to which no response shall be filed unless ordered by the Court), any party opposing a motion must serve and file a memorandum of law in response, and, if necessary to support assertions of fact, affidavits and depositions, not later than fourteen (14) days after service of the motion, except, that in cases of a motion for summary judgment, that time shall be twenty-one (21) days after the service of the motion, unless otherwise ordered by the Court. The response shall not exceed twenty-five (25) pages without leave of Court. If a timely response is not filed, the motion shall be deemed to be unopposed, except for motions to reconsider for which no response shall be permitted unless ordered by the Court. M.D. Tenn. L.R. 7.01(a)(3) (emphasis added). However, the Sixth Circuit has opined that a motion for reconsideration of an interlocutory order may be properly raised under Rule 54(b). Rodriguez v. Tennessee Laborers Health & Welfare Fund, 89 F. App’x 949, 952, 959 (6th Cir. 2004) (“District courts have authority both under common law and Rule 54(b) to reconsider interlocutory orders and to reopen any part of a case before entry of final judgment.”). The Rodriguez court instructs that “courts will find justification for reconsidering interlocutory orders when there is (1) an intervening change of controlling law; (2) new evidence available; or (3) a need to correct a clear error or prevent manifest injustice.” Id. at 959. Welch brings his motion pursuant to the third consideration, a need to correct a clear error. Borrowing from the Sixth Circuit’s instruction on similar Rule 59(e) and 60 motions, see Rodriguez, 89 F. App’x at 959 n.8 (noting district court’s guidance to Rules 59(e) and 60 as reference points to consider prejudice), motions for reconsideration on “reiterated arguments that the court ha[s] previously rejected” are not appropriate. Dassault Systemes, SA v. Childress, 828

F. App’x 229, 249 (6th Cir. 2020); see Johnson v. Unknown Dellatifa, 357 F.3d 539, 544 (6th Cir. 2004) (finding that the district court did not abuse its discretion in denying a Rule 60(b) motion where the movant merely reiterated arguments that he previously made and that the district court had dismissed); Erby v. Kula, 98 F. App’x 405, 407 (6th Cir. 2004) (same); see also Bey v. Johnson Cnty., 2016 WL 11804542, at *1 (E.D. Tenn. Apr. 11, 2016) (applying this principle to a Rule 54(b) motion). By contrast, new arguments “raised for the first time in a motion for reconsideration at the district court [are] generally forfeited.” United States v. Huntington Nat’l Bank, 574 F.3d 329, 331–32 (6th Cir. 2009); see Every v. Brennan, 2018 WL 4568600, at *2 (E.D. Tenn. Sep. 24, 2018) (applying this principle to a Rule 54(b) motions). II. DISCUSSION Welch argues that the Court committed clear, reversable error by: (1) “failing to follow Supreme Court precedent requiring that racial classifications can be subjected to strict scrunty” under Title VI; (2) misstating the bases for Welch’s breach of fiduciary duty claim as articulated

in his papers; and (3) failing to address record evidence supporting Welch’s breach of fiduciary duty claim. (Doc. No. 120-1 at 3, 9). All of Welch’s arguments fail on both procedural and substantive grounds. (See Doc. Nos. 118, 119). As a procedural matter, Welch’s arguments are not properly before the Court. Welch’s first argument on the proper standard to apply to his Title VI claim has already been argued before the Court on four different occasions, all of which the Court has rejected. (Doc. No. 33 at 17–19 (Welch arguing for application of strict scrutiny to Title VI claims in opposition to UNOS’s motion to dismiss); Doc. No. 34 at 19–21 (same in opposition to VUMC’s motion to dismiss); Doc. No. 94 at 18–22 (same in affirmative summary judgment briefing); Doc. No. 113 at 12– 13 (same in response to Defendants’ motion for summary judgment); Doc. No. 118 at 18, 47 (rejecting

application of strict scrutiny analysis to Welch’s Title VI claims)). The same is true for Welch’s argument that the Court misconstrued his breach of fiduciary duty claim. Welch’s response to VUMC’s motion asserted his claim was premised on VUMC’s failure to disclose (Doc. No.

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Bluebook (online)
Welch v. United Network for Organ Sharing, Counsel Stack Legal Research, https://law.counselstack.com/opinion/welch-v-united-network-for-organ-sharing-tnmd-2025.