Gatlin v. Sprinkler Fitters Local 417
- Donovan Frank
- 0:21-cv-01075
- U.S. District Court · District of Minnesota
- 9
In Gatlin v. Sprinkler Fitters Local 417, Judge Frank granted both motions and dismissed Gatlin’s complaint with prejudice.
Doug Gatlin’s claims against Gilbert Mechanical Contractors, Inc. and Sprinkler Fitters Local 417 were dismissed with prejudice; both defendants obtained dismissal.
What happened
In Gatlin v. Sprinkler Fitters Local 417, Doug Gatlin alleged that Gilbert Mechanical Contractors and Sprinkler Fitters Local 417 discriminated against him under federal law because he is African American. He said Gilbert denied him assignments, tools, foreperson duties and pay, made hostile comments, laid him off, and did not return him to work; he also challenged Local 417’s handling of his grievances and work referrals.
Gilbert argued that Gatlin filed too late. The court agreed, finding that Gatlin’s claims arose no later than his November 2016 layoff and were subject to a four-year deadline. The court rejected his arguments about later hiring, a continuing violation, Minnesota’s pandemic-related extensions, and equitable tolling. The court also found that Gatlin failed to state a claim against Local 417 and would not be able to fix his claims against Gilbert through an amended complaint.
Judge Donovan W. Frank granted Gilbert’s and Local 417’s motions to dismiss and dismissed Gatlin’s complaint with prejudice. The order treated Gatlin’s late response to Local 417’s motion as procedurally defective and did not consider it.
The detailed version
- Gatlin v. Sprinkler Fitters Local 417 · No. 0:21-cv-01075
- Donovan Frank
- Jan. 25, 2022
Background
Doug Gatlin sued Sprinkler Fitters Local 417 and Gilbert Mechanical Contractors, Inc. under 42 U.S.C. § 1981, a federal law that prohibits racial discrimination in making and enforcing contracts. The case was removed from Minnesota state court to federal court because the complaint alleged violations of federal law.
Gatlin alleged that he worked for Gilbert from July 2016 until Gilbert laid him off in November 2016. He alleged that Gilbert discriminated against him in work assignments, access to tools and equipment, foreperson duties and wages, workplace treatment, accusations of misconduct, and the layoff. He also alleged that Gilbert hired or continued to employ white sprinkler fitters after his layoff. Gatlin claimed that Local 417 improperly handled grievances about discrimination and failed to refer him for work.
Motions and procedural ruling
Gilbert moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not state a legally sufficient claim. The court declined to consider Gatlin’s opposition to Local 417’s motion because it was filed nearly three weeks after the final deadline and Gatlin had not shown good cause or excusable neglect for the delay.
Claims against Gilbert
Gilbert argued that Gatlin’s § 1981 claims were barred by the applicable four-year statute of limitations. The court agreed. It found that Gatlin’s allegations described discrimination through his November 2016 layoff and did not allege a § 1981 violation after that time. The court stated that Gatlin therefore needed to file by November 2020 but filed approximately five months too late.
The court rejected Gatlin’s argument that later hiring of white sprinkler fitters created a continuing violation. It found that the complaint did not allege that Gatlin applied for a position after November 2016, remained available or interested in returning, or was affirmatively denied reemployment. The court also rejected reliance on Minnesota pandemic-related extensions because state law could not change the federal deadline applicable to § 1981 claims. It further rejected equitable tolling, meaning an extension of the filing deadline based on fairness, because confusion about the applicable deadline did not justify it.
The court concluded that the complaint was untimely and that any amendment would be futile. It dismissed the complaint against Gilbert with prejudice, meaning the court barred refiling those claims in an amended complaint in this action.
Claims against Local 417
The court concluded that Gatlin failed to state a claim against Local 417 based on the alleged grievance handling and work-referral conduct. The court noted that Gatlin had previously brought similar claims and that those claims had been dismissed. It dismissed the complaint against Local 417 with prejudice.
Disposition
The court granted Gilbert’s motion to dismiss and granted Sprinkler Fitters Local 417’s motion to dismiss. It dismissed Gatlin’s complaint with prejudice and directed that judgment be entered. The opinion’s discussion and conclusion refer in places to “Local 407,” but the caption, motion, and order identify the defendant as Sprinkler Fitters Local 417.
Read the full 9-page opinion on CourtListener, the free public archive maintained by the Free Law Project.