Wilson v. Southwest Airlines Co.

98 F.R.D. 725, 37 Fed. R. Serv. 2d 191, 1983 U.S. Dist. LEXIS 14759, 33 Empl. Prac. Dec. (CCH) 34,002, 32 Fair Empl. Prac. Cas. (BNA) 1081
CourtDistrict Court, N.D. Texas
DecidedAugust 10, 1983
DocketCiv. A. No. CA 3-80-0680-G
StatusPublished

This text of 98 F.R.D. 725 (Wilson v. Southwest Airlines Co.) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Wilson v. Southwest Airlines Co., 98 F.R.D. 725, 37 Fed. R. Serv. 2d 191, 1983 U.S. Dist. LEXIS 14759, 33 Empl. Prac. Dec. (CCH) 34,002, 32 Fair Empl. Prac. Cas. (BNA) 1081 (N.D. Tex. 1983).

Opinion

MEMORANDUM ORDER

FISH, District Judge.

The Transport Workers Union of America, AFL-CIO (“Union”) seeks leave to intervene after settlement of this Title VII class action. The motion is opposed by the plaintiff class. The court conducted an evidentiary hearing on the motion on May 27, 1983. For the reasons to be stated, the Union’s motion for leave to intervene is GRANTED.

Procedural Background

This class action was filed by plaintiff Gregory R. Wilson on June 3, 1980. In his complaint, Wilson alleged that Southwest had been guilty of sex discrimination under Title VII because of its refusal to hire males as flight attendants and ticket agents and because of the disparate impact its 5'9" maximum height requirement had on the employability of males. By order of February 9, 1981 the court certified a class consisting of “[a]ll males who have applied to Southwest Airlines for a position as flight attendant or ticket agent and were not notified of rejection before March 9, 1979.”

After trial of the liability issues (Phase I), the court issued a memorandum order on June 12, 1981.1 In that opinion, the court held that exclusion of males from the positions in question violated Title VII’s prohibition against sex discrimination and was not justified by the bona fide occupational qualification defense. The court also held invalid Southwest’s height requirements for flight attendants.

Following the court’s decision, the parties entered into negotiations to settle the relief phase of the case. These negotiations commenced during the summer of 1981 and continued for at least seven months. On May 3, 1982, the parties received tentative court approval of a post trial settlement decree. After a hearing, the court approved the proposed decree by order of July 2, 1982, finding it a fair, reasonable and adequate compromise.

The Union’s Right to Intervene

The Union seeks leave to intervene in this case on the basis of Rule 24(a)(2), Fed.R.Civ.P. According to that rule, the Union is entitled to timely intervention as a matter of right if it meets all three of the following requirements:

1. If it claims an interest relating to the property or transaction which is the subject of the action;
[727]*7272. If it is so situated that the disposition of the action may as a practical matter impair or impede its ability to protect that interest; and
3. If its interest is not adequately represented by existing parties.

Only requirement three is contested by the parties. The Union claims that the seniority rights of its members were not adequately represented before settlement of this case was approved by the court.2 In reply, the plaintiff class maintains that the Union’s position, viz., that only victims of discrimination should be awarded retroactive seniority, was adequately represented by Southwest during settlement negotiations.

Because the court was not privy to the negotiations leading up to the proposed settlement, it cannot determine whether Southwest ever objected to the award of retroactive seniority to non-victims. At the July 1982 hearing on the fairness of the settlement, no one mentioned the provision awarding retroactive seniority to non-discriminatees. At the May 27, 1983 evidentiary hearing on the Union’s motion to intervene, the only evidence on this issue was the conclusionary statement of plaintiffs’ counsel that Southwest had adequately represented the Union’s position. This statement did not specifically answer the question whether Southwest ever bargained for the particular right the Union now asserts. Counsel for Southwest represented to the court at the May 27 hearing that it could live with the present decree or as sought to be modified by the Union. Counsel for Southwest also declined to present any witnesses and only briefly cross-examined one of plaintiffs’ counsel.3 Given Southwest’s lack of a position at the May 27, 1983 hearing on the issue of retroactive seniority and the court’s consequent inability to ascertain whether, during the settlement negotiations, Southwest adequately represented the Union’s interest, the court must conclude that the interest of the Union’s members in protecting their seniority rights against all persons except victims of discrimination was not adequately represented by Southwest. Thus, the Union has sufficiently established its right to intervene and its motion should be granted if the motion can be considered timely.

Timeliness of the Union’s Motion to Intervene

Even where a party is entitled to intervene as a matter of right, Rule 24 requires that the application for intervention be timely. The leading case on timeliness under Rule 24 in the Fifth Circuit is Stallworth v. Monsanto Co., 558 F.2d 257 (5th Cir.1977). See also the recent case of Lelsz v. Kavanagh, 710 F.2d 1040 (5th Cir.1983). Though timeliness is not limited to chronological considerations but is to be determined from all the circumstances, Stall-worth establishes four factors as guidelines in determining the timeliness issue. For purposes of clarity, each of these four factors will be discussed separately in connection with the facts of this case.

FACTOR 1: The length of time during which the Union actually knew or reasonably should have known of its inter[728]*728est in the case before it petitioned for .leave to intervene.

Under this factor, the initial date is not when the Union became aware of the suit but the date on which the Union learned of its interest in the case. Determination of that date depends on the meaning of “its interest.” Simply put, the question is the specificity of the Union’s knowledge, actual or constructive, about the pending case before it moved to intervene.

In making this determination, the court is guided by the following language from Stallworth.

[A] rule making knowledge of the pend-ency of the litigation the critical event . .. would induce both too much and too little intervention. It would encourage individuals to seek intervention at a time when they ordinarily can possess only a small amount of information concerning the character and potential ramifications of the lawsuit, and when the probability that they will misjudge the need for intervention is correspondingly high. Often the protective step of seeking intervention will later prove to have been unnecessary, and the result will be needless prejudice to the existing parties and the would-be intervenor if his motion is granted, and purposeless appeals if his motion is denied. In either event, scarce judicial resources would be squandered, and the litigation costs of the parties would be increased [emphasis added].

Stallworth, above, at 264-265.

The evidence at the May 27 hearing showed that local representatives of the Union were aware of the allegations in plaintiff Wilson’s original complaint within a few days after it was filed.

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98 F.R.D. 725, 37 Fed. R. Serv. 2d 191, 1983 U.S. Dist. LEXIS 14759, 33 Empl. Prac. Dec. (CCH) 34,002, 32 Fair Empl. Prac. Cas. (BNA) 1081, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wilson-v-southwest-airlines-co-txnd-1983.