Carter v. National Collegiate Athletic Association
- Richard Seeborg
- 3:23-cv-06325
- U.S. District Court · Northern District of California
- 2
In Carter v. National Collegiate Athletic Association, Judge Seeborg allowed limited intervention but denied transfer, dismissal, or a stay under the first-to-file rule.
The order affected the Fontenot plaintiffs, who were allowed to intervene for a limited purpose, and the parties in Carter, whose case was not transferred, dismissed, or stayed under the first-to-file rule.
What happened
In Carter v. National Collegiate Athletic Association, plaintiffs from a similar class action in Colorado asked to intervene only to seek transfer, dismissal, or a stay of this case. Their request relied on the first-to-file rule, which can favor an earlier-filed case when related lawsuits overlap.
The court allowed those plaintiffs to intervene for that limited purpose. It then denied their motion because the two cases were filed only 17 days apart, reducing the importance of which case came first. The court also noted that related litigation about compensation and benefits for National Collegiate Athletic Association student-athletes had been ongoing in the Northern District of California.
Judge Richard Seeborg ruled that the circumstances did not justify transferring, dismissing, or staying this case in favor of the Colorado action. The court suggested that judicial efficiency might support litigating the cases together, but said that possibility did not justify applying the first-to-file rule here.
The detailed version
- Carter v. National Collegiate Athletic Association · No. 3:23-cv-06325
- Richard Seeborg
- Apr. 29, 2024
Background
Alex Fontenot and Mya Hollingshed were named plaintiffs in a putative class action pending in the District of Colorado. That action raised claims substantially similar to those in Carter and involved the same defendants. The Fontenot plaintiffs asked to intervene in Carter for the limited purpose of filing a motion to transfer, dismiss, or stay the case under the first-to-file rule.
The first-to-file rule is a case-management principle that may give priority to an earlier-filed action when two courts are handling substantially related cases. The Colorado action was filed before Carter, but the two actions were filed only 17 days apart.
Ruling
The court granted the Fontenot plaintiffs' request for limited intervention. It allowed them to participate for the purpose of presenting their motion to transfer, dismiss, or stay.
The court denied that motion. It reasoned that the short time between the filings greatly reduced the significance of the first-to-file rule because the two cases would not necessarily have progressed to different stages. The court also considered the Fontenot complaint's acknowledgment that compensation and benefits for National Collegiate Athletic Association student-athletes, and the application of antitrust law to those issues, had been the subject of ongoing litigation originating in the Northern District of California for several years.
The court recognized that judicial efficiency and economy might be served if the Colorado case and Carter were litigated together. It stated that the District of Colorado could consider that issue when evaluating a motion to transfer filed by defendants in the Colorado case. But the court concluded that this consideration did not justify transferring, dismissing, or staying Carter under the requested application of the first-to-file rule.
Disposition
Judge Richard Seeborg granted the motion for limited intervention and denied the motion to transfer, dismiss, or stay. The order did not decide the underlying antitrust claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.