Hartman et al v. Santa Clara County et al
Filing
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Order by Judge Araceli Martinez-Olguin denying 139 Motion for Equitable Relief and denying as moot 150 Motion to Shorten Time. (ads, COURT STAFF) (Filed on 6/3/2024)
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SHANNON HARTMAN, et al.,
Plaintiffs,
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v.
SANTA CLARA COUNTY, et al.,
Defendants.
United States District Court
Northern District of California
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Case No. 22-cv-01591-AMO
ORDER DENYING MOTION FOR
EQUITABLE RELIEF AND DENYING
AS MOOT MOTION TO SHORTEN
TIME
Re: Dkt. Nos. 139, 150
Before the Court is Plaintiff Katie Lightfoot’s motion for equitable relief. While Title VII
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authorizes equitable remedies, such as reinstatement, those remedies are ordered “[i]f the court
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finds that the respondent has intentionally engaged in or is intentionally engaging in an unlawful
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employment practice charged in the complaint[.]” See 42 U.S.C. § 2000e-5(g)(1); see also
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Proctor v. Consol. Freightways Corp. of Delaware, 942 F.2d 793 (9th Cir. 1991) (“If
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discrimination has occurred, Title VII aims to make the victims of unlawful discrimination whole
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by restoring them, so far as possible, to a position where they would have been were it not for the
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unlawful discrimination.”) (table decision). Here, no such finding has been made. Thus,
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assuming, without deciding, that Lightfoot still has a Title VII claim available to her in this case,
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the instant motion for equitable relief is premature prior to a liability determination and is
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therefore DENIED. See E.E.O.C. v. Goodyear Aerospace Corp., 813 F.2d 1539, 1544-45 (9th
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Cir. 1987) (reversing and remanding district court’s denial of permanent injunction where
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questions remained about the defendant’s liability, with instructions that “[i]f the EEOC proves its
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case, and Goodyear fails to prove the violation will likely not recur, the EEOC will be entitled to
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an injunction.”).
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To the extent Lightfoot seeks to, on reply, restyle her motion as one for a preliminary
injunction, it is also DENIED. “[R]estor[ing] the status quo,” as Lightfoot seeks, see ECF 149 at
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10, is not the proper object of a motion for preliminary injunction. See Univ. of Texas v.
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Camenisch, 451 U.S. 390, 395 (1981) (“[I]t is generally inappropriate for a federal court at the
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preliminary-injunction stage to give a final judgment on the merits.”) (citations omitted); see also
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Senate of Cal. v. Mosbacher, 968 F.2d 974, 978 (9th Cir. 1992) (“[a] judgment on the merits in the
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guise of preliminary relief is a highly inappropriate result”) (citations omitted).
United States District Court
Northern District of California
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The Court notes that, in their opposition, Defendants seek dismissal of any claims that are
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duplicative of those pending in a parallel class action. See ECF 145 at 8-13. Lightfoot objects
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that the request is improper and contrary to the sequencing Defendants insisted on during the
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status conference held May 8, 2024. See ECF 149 at 7. As discussed at length during that setting,
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Defendants may file a separate motion to the extent they seek dismissal of any of Plaintiffs’ claims
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on the ground that they are duplicative of those asserted in the parallel class case.
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IT IS SO ORDERED.
Dated: June 3, 2024
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ARACELI MARTÍNEZ-OLGUÍN
United States District Judge
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