Keophommasane v. Carnahan
- Analisa Torres
- 1:22-cv-00743
- U.S. District Court · Southern District of New York
- 2
In Keophommasane v. Carnahan, Judge Torres consolidated two related employment-discrimination cases for all purposes.
The consolidation affects Viengkeo Keophommasane and the defendants in the two actions: Robin Carnahan, Administrator of the General Services Administration, and Shari Mauney, Assistant General Counsel. The cases will proceed together, with 22 Civ. 743 as the lead case.
What happened
Keophommasane v. Carnahan involves two cases in which Viengkeo Keophommasane alleges that the defendants failed to promote her in violation of federal age and employment-discrimination laws.
Keophommasane opposed combining the cases, explaining that they concerned two separate job announcements and involved different people in the promotion decisions. The court found that both cases raised the same legal claims against the same defendants and shared important legal and factual questions.
Judge Analisa Torres ordered the cases consolidated for all purposes under the federal rule governing related cases. The clerk was directed to use 22 Civ. 743 as the lead case.
The detailed version
- Keophommasane v. Carnahan · No. 1:22-cv-00743
- Analisa Torres
- Feb. 23, 2022
Background
Viengkeo Keophommasane filed two actions against Robin Carnahan, Administrator of the General Services Administration, and Shari Mauney, Assistant General Counsel. In both actions, she alleges that the defendants discriminated against her under Title VII of the Civil Rights Act of 1964 and the Age Discrimination in Employment Act by failing to promote her. She stated that the alleged failures involved two separate job announcements and that different individuals participated in the promotion denials.
Consolidation
The court notified the parties that it intended to consolidate the actions and invited opposition. Keophommasane opposed consolidation, arguing that combining the cases would limit discovery and interfere with her ability to develop each case. The court determined that both actions involved the same claims and defendants, common legal questions, and likely some common factual questions.
Ruling
The court concluded that consolidation would avoid unnecessary cost, delay, repetition, and confusion without preventing Keophommasane from fully litigating both claims. Judge Analisa Torres ordered that the two actions be CONSOLIDATED for all purposes under Federal Rule of Civil Procedure 42(a). The clerk was directed to consolidate the actions with 22 Civ. 743 as the lead case.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.