throbber
Case 2:22-cv-12761-MAG-EAS ECF No. 15, PageID.124 Filed 12/21/22 Page 1 of 14
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF MICHIGAN
`
`ELIZABETH K. KERWIN, Regional
`Director, Seventh Region of the
`National Labor Relations Board,
`for and on behalf of the
`NATIONAL LABOR RELATIONS
`BOARD,
`
`Petitioner,
`
`Case No. 2:22-cv-12761
`Judge Mark A. Goldsmith
`
`Hon. Mag. Elizabeth A. Stafford
`RESPONDENT STARBUCKS
`CORPORATION’S PARTIAL
`OPPOSITION TO MOTION OF
`WORKERS UNITED FOR LEAVE
`TO APPEAR AS AMICUS
`CURIAE
`
`
`
`v.
`STARBUCKS CORPORATION,
`Respondent.
`__________________________________________________________________
`Patricia A. Fedewa (MI Bar P51964)
`Erik C. Hult (OH Bar 0084056)
`Patrick V. McNamara Building
`Angelique Paul Newcomb (OH Bar
`477 Michigan Avenue, Room 300
`No. 0068094)
`Detroit, MI 48226
`Neil B. Pioch (MI Bar P67677)
`Telephone: (313) 335-8053
`LITTLER MENDELSON, P.C.
`patricia.fedewa@nlrb.gov
`41 South High Street, Suite 3250
`Columbus, OH 43215
`Counsel for Petitioner
`Telephone: (614) 463.4241
`National Labor Relations Board,
`ehult@littler.com
`Region 7
`
`anewcomb@littler.com
`David P. Lichtman (IL Bar 6290051)
`npioch@littler.com
`Elizabeth L. Rowe (IL Bar 6316967)
`Attorneys for Respondent Starbucks Co.
`DOWD, BLOCH, BENNETT,
`John R. Canzano (MI Bar P30417)
`CERVONE, AUERBACH, YOKICH,
`Benjamin L. King (MI Bar P81823)
`LLP
`MCKNIGHT, CANZANO, SMITH,
`8. S. Michigan Avenue
`RADTKE & BRAULT, P.C.
`Chicago, IL 60603
`423 N. Main Street, #200
`Telephone: (312) 372-1361
`Royal Oak, MI 48067
`dlichtman@laboradvocates.com
`Telephone: (248) 354-9650
`erowe@laboradvocates.com
`jcanzano@michworkerlaw.com
`Attorneys for Workers United
`bking@michworkerlaw.com
`Local Counsel for Workers United
`
`

`

`Case 2:22-cv-12761-MAG-EAS ECF No. 15, PageID.125 Filed 12/21/22 Page 2 of 14
`
`1.
`
`On December 8, 2022, Workers United (the “Union”) filed a Motion
`
`for Leave to Appear as Amicus Curiae (“the Motion”) seeking the Court’s
`
`permission “to participate in oral argument at any hearings, to file brief (if it believes
`
`that doing so would be of aid to the Court), and to examine witnesses during any
`
`hearings.” (Dkt. 9, PageID 105).
`
`2.
`
`Respondent Starbucks Corporation partially opposes the Motion to the
`
`extent the Union seeks permission to examine witnesses at hearing because the
`
`Union’s requested level of participation goes far beyond the traditional and well-
`
`accepted limitations on the role of an amicus curiae. The Court should limit the
`
`Union’s amicus participation (if any) to briefing and oral argument only.
`
`
`
`DATED: December 21, 2022
`
`
`
`
`
`Respectfully submitted,
`
`/s/Neil B. Pioch
`Neil B. Pioch (MI Bar No. P67677)
`LITTLER MENDELSON, P.C.
`200 Renaissance Center, Suite 3110
`Detroit, MI 48243-1301
`Telephone: 313.202.3180
`Email: npioch@littler.com
`
`Erik C. Hult (OH Bar No. 0084056)
`Angelique Paul Newcomb (OH Bar
`No. 0068094)
`LITTLER MENDELSON, P.C.
`41 South High Street, Suite 3250
`Columbus, OH 43215
`Telephone: 614.463.4241
`Email:
`ehult@littler.com
`
`
`anewcomb@littler.com
` Attorneys for Respondent Starbucks Corp.
`2
`
`

`

`Case 2:22-cv-12761-MAG-EAS ECF No. 15, PageID.126 Filed 12/21/22 Page 3 of 14
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF MICHIGAN
`
`ELIZABETH K. KERWIN, Regional
`Director, Seventh Region of the
`National Labor Relations Board,
`for and on behalf of the
`NATIONAL LABOR RELATIONS
`BOARD,
`
`Petitioner,
`
`
`
`v.
`STARBUCKS CORPORATION,
`Respondent.
`
`Case No. 2:22-cv-12761
`Judge Mark A. Goldsmith
`
`Hon. Mag. Elizabeth A. Stafford
`MEMORANDUM BRIEF IN
`SUPPORT OF RESPONDENT
`STARBUCKS CORPORATION’S
`PARTIAL OPPOSITION TO
`MOTION OF WORKERS UNITED
`FOR LEAVE TO APPEAR AS
`AMICUS CURIAE
`_____________________________________________________________________________________
`Patricia A. Fedewa (MI Bar P51964)
`Erik C. Hult (OH Bar 0084056)
`Patrick V. McNamara Building
`Angelique Paul Newcomb (OH Bar
`477 Michigan Avenue, Room 300
`No. 0068094)
`Detroit, MI 48226
`Neil B. Pioch (MI Bar P67677)
`Telephone: (313) 335-8053
`41 South High Street, Suite 3250
`patricia.fedewa@nlrb.gov
`Columbus, OH 43215
`Telephone: (614) 463.4241
`Counsel for Petitioner
`Facsimile: (614) 455-9586
`National Labor Relations Board,
`ehult@littler.com
`Region 7
`
`npioch@littler.com
`David P. Lichtman (IL Bar 6290051)
`Attorneys for Respondent Starbucks Co.
`Elizabeth L. Rowe (IL Bar 6316967)
`John R. Canzano (MI Bar P30417)
`DOWD, BLOCH, BENNETT,
`Benjamin L. King (MI Bar P81823)
`CERVONE, AUERBACH, YOKICH,
`MCKNIGHT, CANZANO, SMITH,
`LLP
`RADTKE & BRAULT, P.C.
`8. S. Michigan Avenue
`423 N. Main Street, #200
`Chicago, IL 60603
`Royal Oak, MI 48067
`Telephone: (312) 372-1361
`Telephone: (248) 354-9650
`dlichtman@laboradvocates.com
`jcanzano@michworkerlaw.com
`erowe@laboradvocates.com
`bking@michworkerlaw.com
`Attorneys for Workers United
`Local Counsel for Workers United
`
`

`

`Case 2:22-cv-12761-MAG-EAS ECF No. 15, PageID.127 Filed 12/21/22 Page 4 of 14
`
`TABLE OF CONTENTS
`Table of Contents…………………………………………………………………ii
`Index of Authorities………………………………………………………………iii
`Counterstatement of Questions Presented and Controlling Authorities…………..iv
`Background Facts…………………………………………………………………..1
`Law and Argument…………………………………………………………………2
`A. The Court Should Deny the Union’s Request for Adversarial Amicus
` Status………………………………………………………………….....2
`B. The Union’s Case Law Supporting its Request for Adversarial Amicus
` Status Are Distinguishable…………………………………………….…5
`Conclusion………………………………………………………………………….7
`Certificate of Service……………………………………………………………….8
`
`
`
`
`
`ii
`
`

`

`Case 2:22-cv-12761-MAG-EAS ECF No. 15, PageID.128 Filed 12/21/22 Page 5 of 14
`
`INDEX OF AUTHORITIES
`
`Statutes
`Section 10(j) of the National Labor Relations Act, 29 U.S.C. § 160……………1, 4
`
`Cases
`Davis v. Balson, 461 F. Supp. 842, 847 (N.D. Ohio 1978)………………………...6
`Dunbar v. Landis Plastics, Inc., 996 F. Supp. 174, 180 (N.D.N.Y. 1998)…………6
`EEOC v. Boeing Co., 109 F.R.D. 6, 8-9, 11 (W.D. Wash 1985)………………..…7
`Gandee v. Glaser, 785 F. Supp. 684, 686 (S.D. Ohio 1992), aff’d, 19 F.3d 1432
`(6th Cir. 1994)……………………………………………………………….…..2, 3
`Gottfried v. Mayco Plastics, Inc., 472 F. Supp. 1161, 1163 (E.D. Mich. 1979)…...6
`McKinney v. Starbucks Corporation, No. 2:22-cv-2292, 2022 U.S. Dist. LEXIS
`181091 (W.D. Tenn. Aug. 18, 2022)…………………………………………….4, 5
`McLeod v. General Electric Company, 257 F. Supp. 690, n.1 (S.D.N.Y. 1966)…..6
`NLRB v. Ona Corp., 605 F. Supp. 874, 876 (N.D. Ala. 1985)……………………..6
`Russell v. Bd. of Plumbing Examiners of Cnty. of Westchester, 74 F. Supp. 2d 349,
`361 (S.D.N.Y. 1999), aff’d, 1 F. App’x 38 (2d Cir. 2001)……………………2, 3, 5
`United States v. State of Mich., 940 F.2d 143, 164-165 (6th Cir. 1991)……...2, 3, 5
`Zipp v. Caterpillar, Inc., 858 F. Supp. 794 (C.D. Ill. 1994)………………………..6
`
`Rules
`Fed. R. Civ. P. 14…………………………………………………………………..3
`Fed. R. Civ. P. 24………………………………………….……………………….4
`Fed. R. Civ. P. 17-25………………………………………………...……………..3
`
`
`
`
`
`
`
`iii
`
`

`

`Case 2:22-cv-12761-MAG-EAS ECF No. 15, PageID.129 Filed 12/21/22 Page 6 of 14
`
`
`
`
`
`
`COUNTERSTATEMENT OF QUESTIONS PRESENTED AND
`CONTROLLING AUTHORITIES
`I. Whether this Court should limit the Union’s amicus participation (if any)
`to briefing and oral argument only?
`Respondent answers, “Yes.”
`Claimant and Union answer, “No.”
`This Court should answer, “Yes.”
`Most controlling or persuasive authority: United States v. State of Mich., 940
`F.2d 143, 164-165 (6th Cir. 1991) (historically, participation as amicus curiae
`was intended to “provide impartial information on matters of law about which
`there was doubt, especially in matters of public interest”); McKinney v.
`Starbucks Corporation, No. 2:22-cv-2292 (W.D. Tenn. Aug. 18, 2022)
`(limiting Union’s amicus participation to arguing its position on written brief
`but denying Union’s request to participate in discovery, noting that only an
`intervenor would have that right).
`
`
`
`iv
`
`

`

`Case 2:22-cv-12761-MAG-EAS ECF No. 15, PageID.130 Filed 12/21/22 Page 7 of 14
`
`I.
`
`BACKGROUND FACTS
`
`On November 15, 2022, Region 7 of the National Labor Relations Board
`
`(“NLRB”) filed a Preliminary Injunction Under Section 10(j) of the National Labor
`
`Relations Act (“NLRA” or “the Act”) against Respondent Starbucks Corporation
`
`(“Respondent” or “Starbucks”). On November 17, 2022, the Court issued an Order
`
`to Show Cause, setting December 15, 2022, as the deadline by which Respondent
`
`should file an Answer to the 10(j) Petition and setting January 5, 2023, as the hearing
`
`date on the 10(j) Petition. (Order to Show Cause, Dkt. 3).
`
`On December 1, 2022, Respondent filed an Unopposed Motion for
`
`Continuance requesting a three-week extension of the Answer deadline and hearing
`
`date. (Motion for Continuance, Dkt. 7). On December 2, 2022, the Court issued an
`
`Order Granting Respondent’s Unopposed Motion giving Respondent until January
`
`5, 2023, to answer, move or move in response to Petitioner’s petition and
`
`rescheduling the hearing for February 1, 2023. (Order, Dkt. 8).
`
`On December 8, 2022, Workers United (the “Union”) filed a Motion for Leave
`
`to Appear as Amicus Curiae (“the Motion”) seeking the Court’s permission “to
`
`participate in oral argument at any hearings, to file brief (if it believes that doing so
`
`would be of aid to the Court), and to examine witnesses during any hearings.”
`
`(Motion, Dkt. 9, PageID 105). Respondent partially opposes the Motion to the
`
`extent the Union seeks permission to examine witnesses at any hearing because the
`
`
`
`
`
`

`

`Case 2:22-cv-12761-MAG-EAS ECF No. 15, PageID.131 Filed 12/21/22 Page 8 of 14
`
`Union’s requested level of participation goes far beyond the traditional and well-
`
`accepted limitations on the role of an amicus curiae. The Court should limit the
`
`Union’s amicus participation (if any) to briefing and oral argument only.
`
`II. LAW AND ARGUMENT
`
`A. The Court Should Deny the Union’s Request for Adversarial
`Amicus Status.
`
`
`Historically, participation as amicus curiae was intended to “provide impartial
`
`information on matters of law about which there was doubt, especially in matters of
`
`public interest.” United States v. State of Mich., 940 F.2d 143, 164-165 (6th Cir.
`
`1991). While “some courts have departed from the orthodoxy of amicus curiae as
`
`an impartial friend of the court,” those courts generally only still “have recognized
`
`a very limited adversary support of given issues through brief and/or oral argument.”
`
`Id. at 165 (emphasis in original).
`
`The participation of a party as an amicus is a “privilege within the sound
`
`discretion of the courts” and depends on a “finding that the proffered information of
`
`amicus is timely, useful, or otherwise necessary to the administration of justice.” Id.
`
`(internal quotations omitted); Gandee v. Glaser, 785 F. Supp. 684, 686 (S.D. Ohio
`
`1992), aff’d, 19 F.3d 1432 (6th Cir. 1994) (“[T]he scope of amicus’ participation [is]
`
`discretionary.”); see also Russell v. Bd. of Plumbing Examiners of Cnty. of
`
`Westchester, 74 F. Supp. 2d 349, 361 (S.D.N.Y. 1999), aff’d, 1 F. App’x 38 (2d Cir.
`
`2001) (noting the court “has the discretion to determine the extent and manner of
`2
`
`
`
`

`

`Case 2:22-cv-12761-MAG-EAS ECF No. 15, PageID.132 Filed 12/21/22 Page 9 of 14
`
`participation of an amicus”). However, there should remain an important distinction
`
`between amicus curiae and named parties or real parties in interest in a proceeding.
`
`An amicus should not be permitted to participate in a way that rises to the level of a
`
`named party or a real party in interest without complying with the requirements of
`
`Rules 14, and 17-25 of the Federal Rules of Civil Procedure. See State of Mich., 940
`
`F.2d at 165 (“Amicus . . . has never been recognized, elevated to, or accorded the
`
`full litigating status of a named party or a real party in interest, . . . and amicus has
`
`been consistently precluded from initiating legal proceedings, filing pleadings, or
`
`otherwise participating and assuming control of the controversy in a totally
`
`adversarial fashion.” (Internal citations omitted).
`
`Amicus participation is appropriately limited in situations where the Court is
`
`comfortable with the adequacy of the parties to present their respective positions,
`
`the evidence from the amicus would be prejudicial and/or redundant, the amicus
`
`would be assuming a fully adversarial position, or participation of the amicus would
`
`slow or complicate the progress of the action. See e.g., Gandee, 785 F. Supp. at 686
`
`(excluding evidence offered by amicus due to stage of litigation, the adequacy of the
`
`state’s defense, and prejudice and redundancy); Russell, 74 F. Supp. 2d at 351
`
`(noting an amicus “has no personal, legally protectable interest in the outcome of the
`
`litigation”). Such considerations for limiting amicus participation are present here.
`
`
`
`3
`
`

`

`Case 2:22-cv-12761-MAG-EAS ECF No. 15, PageID.133 Filed 12/21/22 Page 10 of 14
`
`Respondent does not object to the Union’s request for traditional amicus status
`
`to file briefs and participate in oral argument (if any). However, it opposes the
`
`Union’s request to participate in the proceedings in an adversarial fashion by
`
`examining witnesses at hearing for three reasons. First, the request is improper
`
`because it would effectively permit the Union to act as an intervening party without
`
`meeting the requirements of Rule 24 of the Federal Rules of Civil Procedure.
`
`Second, the request is unnecessary. The Union has shown no reason why Petitioner
`
`cannot adequately examine witnesses and present evidence at hearing to support its
`
`position on the injunctive relief sought and to adequately protect the interests of the
`
`workers whom the Union represents. Third, allowing the Union to act as an
`
`intervenor and participate in an adversarial fashion by examining witnesses at
`
`hearing is likely to be duplicative of Petitioner’s efforts and will serve only to
`
`unnecessarily lengthen and complicate the proceedings.
`
`The Union argues that the Court should grant its Motion because it was
`
`granted amicus status in a similar Section 10(j) proceeding against Respondent in
`
`McKinney v. Starbucks Corporation, No. 2:22-cv-2292, 2022 U.S. Dist. LEXIS
`
`181091 (W.D. Tenn. Aug. 18, 2022) (Motion, Dkt. 9, PageID 110). There, the Union
`
`took a slightly different approach, seeking to intervene in the proceedings and/or
`
`participate as amicus curiae (Motion of Workers United to Intervene or, in the
`
`Alternative, to Participate as Amicus Curiae, No. 2:22-cv-2292, Dkt. 20) (Ex. A)
`
`
`
`4
`
`

`

`Case 2:22-cv-12761-MAG-EAS ECF No. 15, PageID.134 Filed 12/21/22 Page 11 of 14
`
`and it expressly sought permission to “offer evidence at hearing and participate in
`
`all discovery.” (Id. at PageID 394). The United States District Court for the
`
`Western District of Tennessee (Lipman, J.) denied the Union’s motion to intervene.
`
`(Order Denying in Part and Granting in Part Motion of Workers United to Intervene
`
`or, in the Alternative, to Participate as Amicus Curiae, No. 2:22-cv-2292 (W.D.
`
`Tenn.), Dkt. 45, PageID 481-482) (Ex. B). Citing the precedential standard set by
`
`the Sixth Circuit in State of Mich., the Court granted the Union’s motion to
`
`participate as amicus but not without placing appropriate boundaries on its amicus
`
`participation. The Court held that the Union’s amicus participation was limited to
`
`arguing its position on written brief and that the Union was entitled to receive
`
`informational copies of the Parties’ docket filings (and the materials they reference).
`
`(Id. at PageID 484, citing State of Mich., 940 F.2d at 166-167). The Court flatly
`
`denied the Union’s request to participate in discovery, noting that only an intervenor
`
`would have that right. (Id. at PageID 485, citing Russell, 74 F. Supp. 2d at 351).
`
`Should the Court grant the Union’s Motion, it should similarly limit the Union’s role
`
`as amicus to filing briefs and participating in oral argument (if any).
`
`B.
`
`The Union’s Case Law Supporting its Request for Adversarial
`Amicus Status Are Distinguishable.
`
`In its Motion, the Union cites a litany of cases to support its argument that it
`
`should be granted amicus status to actively participate in the proceedings. (Motion,
`
`Dkt. 9, PageID 111-112). However, in most of these cases, the participation of the
`5
`
`
`
`

`

`Case 2:22-cv-12761-MAG-EAS ECF No. 15, PageID.135 Filed 12/21/22 Page 12 of 14
`
`amicus was limited to the traditional role of filing legal memoranda and participating
`
`in oral argument. See e.g., Dunbar v. Landis Plastics, Inc., 996 F. Supp. 174, 180
`
`(N.D.N.Y. 1998) (“I . . . grant the union permission to appear in this matter as amicus
`
`curiae. The union is permitted to file memoranda and evidentiary affidavits and to
`
`participate in any future oral arguments.”); D’Amico v. United States Services
`
`Industries, Inc., 867 F. Supp. 1075, 1079 (D.D.C. 1994) (SEIU “sought leave to file
`
`a brief as amicus curiae, and the Court granted the unopposed motion.”); Zipp v.
`
`Caterpillar, Inc., 858 F. Supp. 794 (C.D. Ill. 1994) (the UAW “filed an amicus brief
`
`in support of the Second Amended Petition.”); Gottfried v. Mayco Plastics, Inc., 472
`
`F. Supp. 1161, 1163 (E.D. Mich. 1979) (“the court denied the motion of the UAW
`
`to intervene in the case, but granted it the right to file briefs amicus curiae and to be
`
`heard on the form of any orders.”).
`
`The handful of cases cited by the Union where the amicus was given a more
`
`adversarial role are distinguishable. In NLRB v. Ona Corp., 605 F. Supp. 874 (N.D.
`
`Ala. 1985), the Court gave the parties, not the amicus, a “full opportunity to be
`
`heard, to examine and cross-examine witnesses and present evidence bearing on the
`
`issues.” Id. at 876. In McLeod v. General Electric Company, 257 F. Supp. 690, n.1
`
`(S.D.N.Y. 1966) and Davis v. Balson, 461 F. Supp. 842, 847 (N.D. Ohio 1978), the
`
`entities seeking amicus status (the union in McLeod and the United States in Davis)
`
`were permitted to engage in discovery, examine witnesses and file briefs; however,
`
`
`
`6
`
`

`

`Case 2:22-cv-12761-MAG-EAS ECF No. 15, PageID.136 Filed 12/21/22 Page 13 of 14
`
`it is unclear whether that was by agreement of the parties. Here, Respondent does
`
`not agree that the Union should be accorded the adversarial level of participation it
`
`seeks, nor has it demonstrated any compelling need to do so. Finally, in EEOC v.
`
`Boeing Co., 109 F.R.D. 6, 8-9 (W.D. Wash 1985), the Court granted a unique
`
`status—somewhere between amicus and intervenor—to counsel representing 16
`
`pilots who had been fired by Boeing for turning 60 because the EEOC was not
`
`consulting the pilots or keeping them informed about the case. Id. at n.2. Even so,
`
`the Court still limited their adversarial participation, holding the pilots’ counsel had
`
`no right to conduct discovery or file motions independently of the EEOC. Id. at 11.
`
`Here, unlike Boeing, there is no basis to conclude that Petitioner is incapable of
`
`adequately representing the Union’s interests and no basis to grant the Union the
`
`unique status it seeks. Rather, if the Court grants the Union’s Motion, Respondent
`
`respectfully requests that the Union’s participation as amicus be limited to filing
`
`briefs and participating in oral argument (if any).
`
`III. CONCLUSION
`
`For the foregoing reasons, the Court should deny Workers United’s request to
`
`examine witnesses at hearing as amicus. Should the Court find it appropriate for
`
`Workers United to participate as amicus, its participation should be limited to filing
`
`briefs and participating in oral argument only.
`
`
`
`
`
`7
`
`

`

`Case 2:22-cv-12761-MAG-EAS ECF No. 15, PageID.137 Filed 12/21/22 Page 14 of 14
`
`
`
`Respectfully submitted,
`
`DATED: December 21, 2022
`
`/s/Neil B. Pioch
`Neil B. Pioch (MI Bar No. P67677)
`LITTLER MENDELSON, P.C.
`200 Renaissance Center, Suite 3110
`Detroit, MI 48243-1301
`Telephone: 313.202.3180
`Facsimile: 313.446-6405
`Email: npioch@littler.com
`
`Erik C. Hult (OH Bar No. 0084056)
`Angelique Paul Newcomb (OH Bar
`No. 0068094)
`LITTLER MENDELSON, P.C.
`41 South High Street, Suite 3250
`Columbus, OH 43215
`Telephone: 614.463.4241
`Facsimile: 614.455-9586
`Email:
`ehult@littler.com
`
`
`anewcomb@littler.com
`
`Attorneys for Respondent
` Starbucks Corporation
`
`CERTIFICATE OF SERVICE
`I certify that on December 21, 2022, I electronically filed the foregoing document(s)
`and that they are available for viewing and downloading from the Court’s CM/ECF
`system, and that all participants in the case are registered CM/ECF users and that
`service will be accomplished by the CM/ECF system.
`
`
`/s/ Neil B. Pioch
`Neil B. Pioch
`
`
`
`
`
`
`
`4888-2829-6517.1 / 055187-2413
`
`
`
`
`8
`
`

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