WILLIAMS v. LINODE LIMITED LIABILITY COMPANY

CourtDistrict Court, E.D. Pennsylvania
DecidedMarch 29, 2024
Docket2:22-cv-01618
StatusUnknown

This text of WILLIAMS v. LINODE LIMITED LIABILITY COMPANY (WILLIAMS v. LINODE LIMITED LIABILITY COMPANY) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
WILLIAMS v. LINODE LIMITED LIABILITY COMPANY, (E.D. Pa. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

CARL WILLIAMS,

, Case No. 2:22-cv-01618-JDW

v.

LINODE LIMITED LIABILITY COMPANY,

et al.,

MEMORANDUM

At a trial, there are at least two sides to every story. That goes without saying because if the “litigants' versions of the case were in harmony, there would have been no need for this trial.” , 887 F. Supp. 709, 721 (D. Del. 1995). After hearing everyone’s story, our judicial system trusts juries to decide what happened. A jury’s deliberations occur in a sanctum. Throughout trial, we tell jurors to avoid any outside information about a case and to decide the case based only on the evidence. And while they deliberate, we cut them off from the outside world. They have no cellphones or computers while they deliberate, just the exhibits, their memories of the testimony, and their common sense. And when they finish, we defer to their decisions, with very narrow exceptions. In this case, each side told its story to a jury over a seven-day trial. Carl Williams told a jury that he experienced pervasive discrimination during his employment at Linode, LLC, and that Linode fired him due to that discrimination. Linode told the jury that it fired Mr. Williams because he had an ongoing relationship with John Musbach, who had been

accused of criminal activity that at least some Linode employees could not stomach. The jury concluded that Mr. Williams didn’t prove his case. Now, Mr. Williams wants a mulligan. He says my rulings before and during trial

deprived him of a fair trial. While briefing that motion, he filed a reply brief that was late and overlength. I told him to shorten it, but Linode wants me to reconsider and strike his reply altogether. I won’t deprive Mr. Williams of his reply. But I also won’t give him a new trial. I’ve reviewed his arguments and the trial record, and I’ve concluded that Mr. Williams

got a fair trial based on admissible evidence. I’ve also concluded that any errors that he posits did not prejudice the trial as a whole. I will therefore deny both Mr. Williams’s motion for a new trial and Linode’s request that I strike Mr. Williams’s reply brief. I. RECONSIDERATION

Mr. Williams filed his reply brief in support of his new trial motion late and overlength. I struck the brief for being overlength and gave him an opportunity to refile. Linode asks me to reconsider that and to bar Mr. Williams’s reply for its lateness. A court

may reconsider a prior ruling if the moving party shows (1) an intervening change in the controlling law, (2) the availability of new evidence that was not available when the court issued its order, or (3) the need to correct a clear error of law or fact or to prevent manifest injustice. , 1 F. Supp. 3d 319, 420 (E.D. Pa. 2014). Courts should grant reconsideration “sparingly.” There’s no new evidence or new law, so presumably Linode thinks I made a clear error or that my ruling is manifestly unjust.

While deadlines are mandates and not suggestions, I balance the need to enforce them with the well-established preference to resolve disputes on the merits. , 732 F.2d 1178, 1181 (3d Cir. 1984). As a result, I have the authority to “extend

a missed deadline if the party seeking the extension shows that it was tardy due to ‘excusable neglect.’” , 649 F. App'x 137, 141 n.3 (3d Cir. 2016) (quoting Fed. R. Civ. P. 6(b)(1)(B)). Under Rule 6(b), excusable neglect may extend to “inadvertent delays” and “is not limited strictly to omissions caused by circumstances

beyond the control of the movant.” , 507 U.S. 380, 392 (1993). Although Mr. Williams does not provide a sufficient reason for his tardiness, his delay was not excessive. Linode suffers no prejudice from it. And Mr. Williams would suffer

substantial prejudice if I did not consider his reply, which is the only chance he has to respond to Linode’s arguments. Because Linode has not articulated a prejudice that it faces from my consideration of Mr. Williams’s reply, I won’t strike the filing.

, 649 F. App'x at 141 n.3. II. NEW TRIAL A. Legal Standard

After a jury trial, a judge may grant a new trial under Rule 59 “for any reason for which a new trial has heretofore been granted in an action at law in federal court.” Fed. R. Civ. P. 59(a)(1)(A). However, the judge will only grant a new trial where the “jury's verdict

resulted in a miscarriage of justice or where the verdict, on the record, cries out to be overturned or shocks our conscience.” , 926 F.2d 1344, 1353 (3d Cir. 1991). Granting a new trial is discretionary. , 316 F.3d 424, 429 (3d Cir. 2003).

In granting a motion for a new trial on the basis of trial error, the judge must consider (1) whether an error was in fact committed and (2) whether that error was so prejudicial that denial of a new trial would be inconsistent with substantial justice. , 709 F. Supp. 600, 601, , 922 F.2d 184 (3d Cir. 1990).

A judge “cannot speculate as to the content of the jury's deliberations.” , 134 F.3d 171, 177 (3d Cir. 1998). The judge must assume the jury understood and followed the instructions it received. ,

57 F.4th 110, 122 (3d Cir. 2023). Absent proof of improper extraneous influence, a judge will not guess or inquire as to the jury's thought process , 760 F.2d 481, 488 (3d Cir. 1984). “Extraneous influences” include communications between the judge and jury outside the presence of counsel. B. Preliminary Matters 1. Post-trial juror comments

After a jury returns a verdict, I often permit counsel for the Parties to speak with jurors who are willing to do so. The opportunity lets counsel get feedback on the substance and style of their performance. The session takes place in the courtroom but

off the record, and it is informal. Some jurors stay, others don’t. I afforded counsel for the Parties in this case that opportunity. Now, Mr. Williams seeks to use what some jurors said during that discussion to support his Motion. To get around the fact that there is no record of the conversations, Mr. Williams’s counsel, Seth Carson, submits a Declaration reporting

on what he claims the jurors said to him, including that the jurors believed Mr. Williams to be “complicit” in Mr. Musbach’s criminal activity. (ECF No. 81-1 at ¶ 20.) At least two problems. , the juror’s statements as related in Mr. Carson’s Declaration are hearsay. They were made out-of-court, in the sense that court was not in

session (even though the conversation happened in the courtroom), and Mr. Williams offers them for their truth. But I have no way of knowing what the jurors said or the context in which they said it. , the jury’s statements don’t matter. It is “well settled … that

the jury's deliberative processes are not legally cognizable, except where subject to extraneous influences.” , 760 F.2d at 488 (internal quotation and citation omitted). Mr. Carson’s Declaration doesn’t suggest that there was any outside influence. It just reports on intra-jury discussions and thought process.

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