William Peterson, III v. Harrah's NC Casino Company, LLC

CourtCourt of Appeals for the Fourth Circuit
DecidedMarch 12, 2026
Docket23-2316
StatusPublished

This text of William Peterson, III v. Harrah's NC Casino Company, LLC (William Peterson, III v. Harrah's NC Casino Company, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
William Peterson, III v. Harrah's NC Casino Company, LLC, (4th Cir. 2026).

Opinion

USCA4 Appeal: 23-2316 Doc: 34 Filed: 03/12/2026 Pg: 1 of 14

PUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 23-2316

WILLIAM PETERSON, III,

Plaintiff – Appellant,

v.

HARRAH’S NC CASINO COMPANY, LLC; CAESARS ENTERTAINMENT, INC.,

Defendants – Appellees.

Appeal from the United States District Court for the Western District of North Carolina, at Asheville. Max O. Cogburn, Jr., District Judge. (1:23-cv-00036-MOC-WCM)

Argued: January 31, 2025 Decided: March 12, 2026

Before GREGORY, RICHARDSON, and RUSHING, Circuit Judges.

Vacated and remanded by published opinion. Judge Rushing wrote the opinion, in which Judge Gregory and Judge Richardson joined.

ARGUED: Daniel Gray Leland, LELAND CONNERS PLC, Minneapolis, Minnesota, for Appellant. Kevin Michael Cleys, LITTLER MENDELSON, P.C., Charlotte, North Carolina, for Appellees. ON BRIEF: Jake Snider, WIMER SNIDER, P.C., Asheville, North Carolina, for Appellant. USCA4 Appeal: 23-2316 Doc: 34 Filed: 03/12/2026 Pg: 2 of 14

RUSHING, Circuit Judge:

Plaintiff William Peterson, III, used to work as a table games dealer at Harrah’s

Cherokee Casino Resort in North Carolina. After he was fired and denied an opportunity

to be rehired, Peterson sued Harrah’s NC Casino Company, LLC, and its corporate parent,

Caesars Entertainment, Inc. (together, Harrah’s), asserting employment discrimination and

retaliation claims under the Family and Medical Leave Act (FMLA), 29 U.S.C. § 2601 et

seq., and the Uniformed Services Employment and Reemployment Rights Act (USERRA),

38 U.S.C. § 4301 et seq. The district court dismissed Peterson’s complaint after finding

that the Tribal Casino Gaming Enterprise (TCGE)—a wholly owned and operated

enterprise of the Eastern Band of Cherokee Indians (Tribe)—is a necessary and

indispensable party to this litigation. See Fed. R. Civ. P. 19. Peterson appealed.

On this record, we conclude that the district court abused its discretion in finding

that TCGE is a necessary party under Rule 19(a). Accordingly, we vacate the district

court’s order dismissing Peterson’s complaint and remand for further proceedings

consistent with this opinion.

I.

A.

Peterson is a United States Army veteran suffering from post-traumatic stress

disorder and major depressive disorder. In 2016, he began working as a table games dealer

at Harrah’s Cherokee Casino Resort. The casino is owned by the Tribe, a federally

recognized Indian tribe. The Tribe, through TCGE, contracts with Defendant Harrah’s NC

Casino Company to “operate[]” the casino. J.A. 8.

2 USCA4 Appeal: 23-2316 Doc: 34 Filed: 03/12/2026 Pg: 3 of 14

One day in early 2021, the casino’s fire alarm went off during Peterson’s shift. As

Peterson “prepared to evacuate,” his supervisor told him and others not to leave and to

continue “deal[ing] hands to customers.” J.A. 10–11. Peterson protested that the

supervisor’s instructions were “illegal,” but the supervisor laughed it off. J.A. 11.

Peterson filed a complaint with casino management, claiming that his supervisor’s

instructions were improper and that “the unsafe environment during the fire alarm . . .

triggered” his PTSD. J.A. 12. About a month later, Peterson requested leave under the

FMLA due to his disability. After being told “not to speak about the FMLA at work” and

waiting “approximately one hour” while his “symptoms worsened,” he was finally allowed

to leave his shift. J.A. 12–13.

A few days later, Peterson filed a complaint with human resources. He reported

management’s “delay in response to his reasonable accommodation request,” his

manager’s “instructions not to discuss [the] FMLA at work,” and his manager’s “rude and

aggressive behavior.” J.A. 13. Peterson participated in a video call with the casino’s

benefits and wellness manager and two human resources supervisors, but they “did not

provide [him] with any information on company policies or expectations regarding

reasonable accommodations or FMLA leave.” J.A. 14. Nor did they “advise[] [him] of

his legal rights, as he had requested.” J.A. 14.

About a month later, in April 2021, Peterson “arrived to work and was immediately

suspended.” J.A. 14. He was terminated four days later and banned from the property for

30 days. “When [Peterson] inquired why he was banned,” he was allegedly told “it was

because of [his] emotional distress, veteran’s status, and health history.” J.A. 14.

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According to Peterson, casino management told him that the casino was “‘taking

precautions’ due to ‘everything going on in the world, with active shooters and terrorism.’”

J.A. 14. Management also told Peterson that he was terminated because he violated the

“company code of conduct, specifically professional judgment, stemming from alleged

incidents on April 16 and 18 with toke bets placed by a player at his table.” J.A. 14.

Peterson was told that he would be eligible for rehire in one year.

A little over a year after he was fired, Peterson applied for and was “offered a

position” at the casino as well as an “interview for another position.” J.A. 15. Just before

his scheduled interview, however, Peterson was informed that “he would not be

interviewing for the position.” J.A. 15. His job offer was then rescinded, and he was told

that “he was no longer eligible for rehire with” the casino. J.A. 15–16. Peterson then filed

this lawsuit.

B.

Peterson sued in the U.S. District Court for the Western District of North Carolina.

His complaint alleged four counts against Harrah’s. Count I alleged that Harrah’s

“engaged in unlawful discriminatory employment practices in violation of the FMLA” by

“terminating [Peterson’s] employment . . . , rescinding a job offer, and refusing to hire him

because of his protected activity.” J.A. 16–17. Count II alleged Harrah’s fired Peterson,

rescinded his job offer, and refused to hire him in retaliation for exercising his FMLA

rights, including the right to “request . . . intermittent FMLA leave.” J.A. 17–18. Count

III alleged that Harrah’s interfered with Peterson’s FMLA rights. And Count IV alleged

that Harrah’s violated USERRA by “terminating [Peterson’s] employment . . . , rescinding

4 USCA4 Appeal: 23-2316 Doc: 34 Filed: 03/12/2026 Pg: 5 of 14

a job offer, and refusing to hire him because of his prior military service.” J.A. 20. As

relief, Peterson requested backpay, compensatory damages, and statutory damages;

reinstatement or, alternatively, front pay; and an order enjoining Harrah’s from its

“unlawful acts.” J.A. 20–21.

Harrah’s moved under Federal Rule of Civil Procedure 12(b)(7) to dismiss

Peterson’s complaint for “failure to join a party under Rule 19.” Fed. R. Civ. P. 12(b)(7).

According to Harrah’s, TCGE—not Harrah’s—was Peterson’s “true employer” and

therefore a necessary party to this suit. J.A. 27. And because TCGE enjoys tribal sovereign

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William Peterson, III v. Harrah's NC Casino Company, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/william-peterson-iii-v-harrahs-nc-casino-company-llc-ca4-2026.