Coger v. Regional Elite Airline Services, LLC
Filing
57
MEMORANDUM OPINION AND ORDER: For the reasons set forth above, the defendants Motion for Summary Judgment 33 is GRANTED. The case is, therefore, dismissed on the merits. See order for details. Signed by District Judge J Ronnie Greer on 3/19/2013. (RLC, )
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF TENNESSEE
AT GREENEVILLE
CRYSTAL COGER,
Plaintiff,
v.
REGIONAL ELITE AIRLINE SERVICES, LLC,
Defendant.
)
)
)
)
)
)
)
)
)
NO.: 2:11-CV-77
MEMORANDUM OPINON AND ORDER
Regional Elite Airline Services, LLC (“defendant” or “Regional Elite”) have filed a
Motion for Summary Judgment, [Doc. 33]. First, the defendant argues in the motion that Crystal
Coger (“plaintiff” or “Coger”) cannot establish a prima facie case of unlawful discharge based on
union animus in violation of the Railway Labor Act (“RLA”). See 45 U.S.C. § 151 et seq.
(2011). Second, using the burden shifting framework of the Wright Line test, the defendant
argues that it would have terminated the plaintiff’s employment regardless of any conduct she
engaged in that may have been protected by the RLA. The plaintiff has filed a response, [Doc.
39]. She argues that she has established a prima facie case and further argues that the Wright
Line test does not apply in RLA cases. The matter is ripe for disposition. For the reasons that
follow, this Court finds that, considering the facts in the light most favorable to the plaintiff as it
must, she survives summary judgment on the elements of a prima facie case. This Court will,
however, utilize the Wright Line test, and in so doing, this Court finds that there is no genuine
issue of material fact as to whether the defendant would have terminated the plaintiff regardless
of any RLA protected activity because she undisputedly violated the defendant’s no-fault
attendance policy. As such, the defendant’s motion is GRANTED, [Doc. 33], and the case is
dismissed on the merits.
I. FACTS
The facts considered in the light most favorable to the plaintiff are as follows.
Mesaba Airlines, later acquired by the Regional Elite, hired Coger as a customer service/ramp
agent (“agent”) at its Tri-Cities Airport station (“TRI”) in Blountville, Tennessee in 2009. Coger
Dep. 95-96. Regional Elite has 25-30 employees. Coger Dep. 111. Coger originally reported to
TRI Station Manager Danny Tatum, but in early 2010, Lisa Senters became the new Station
Manager at TRI. Coger Dep. 108-09. Regional Elite has a no-fault attendance policy, and it is
contained within the Regional Elite Employee Handbook, which is available to all employees on
Regional Elite's employee intranet. Coger Dep. 115-17, Ex. 15; Senters Dep. 46-47. Coger was
familiar with the policy. Coger Dep.114-16, Exs. 14-15.
Under this policy, employees are issued occurrences for unexcused attendance infractions
and may have up to (9) occurrences in a rolling twelve-month period. Coger Dep. 115-17, Ex.
15; Senters Dep. 46-47. There is no grace period for clocking in late for a shift. Coger Dep. 11517, Ex. 15; Senters Dep. 46-47. The first two tardies of 59 minutes or less trigger half (.5) an
occurrence. After two tardies, any further instances of lateness up to 119 minutes result in one
(1) occurrence. Tardies over 120 minutes result in two (2) occurrences. Coger Dep. 115-17, Ex.
15; Senters Dep. 46-47. An unauthorized absence results in one (1) occurrence. If an employee is
absent for two consecutive days and provides appropriate documentation (i.e. physician
statement), the absence will count as one (1) occurrence. Coger Dep. 115-17, Ex. 15; Senters
Dep. 46-47. Employees are required to report absences at least one hour prior to the
scheduled start time. Employees who call in absences less than 60 minutes prior to the scheduled
2
start time will be assigned a second occurrence. Coger Dep. 115-17, Ex. 15; Senters Dep. 4647. Some absences, like absences due to an on the job injury (OJI), are considered an authorized
absence and do not count as an occurrence. Coger Dep. 115-17, Ex. 15; Senters Dep. 46-47. 14.
An employee first incurs discipline (a verbal warning) under the attendance policy when the
employee receives four (4) occurrences in a rolling twelve-month period. Coger Dep. 115-17,
Ex. 15; Senters Dep. 46-47. An employee who incurs six (6) occurrences in a twelve-month
rolling period is issued a written warning under the policy. Coger Dep. 115-17, Ex. 15; Senters
Dep. 46-47. When an employee reaches eight (8) occurrences in a twelve-month rolling period, a
final written warning is issued under the policy. Coger Dep. 115-17, Ex. 15; Senters Dep. 4647. Final warnings remain in effect for 90 days, and occurrences are not dropped from an
employee's file during that period. Coger Dep. 115-17, Ex. 15; Senters Dep. 46-47. Employees
are terminated when they reach nine (9) occurrences in a twelve-month rolling period or when
they incur an additional occurrence during the 90-day final warning period. Coger Dep. 115-17,
Ex. 15; Senters Dep. 46-47.
When Senters became the Station Manager at TRI in 2010 she realized that employees'
attendance records at the station had not been tracked consistently or in some instances at all.
Senters Dep. 45-48. Senters and her Regional Manager decided that TRI employees would all
be retrained on Regional Elite's attendance policy and that their attendance records would all
be brought to zero occurrences. Senters Dep. 45-48. All employees at the TRI station were
required to sign an agreement memorializing that they understood the attendance policy and that
their attendance records would be reset to zero. Coger Dep. 118-19, Ex. 16; Senters Dep. 4748. The agreement indicated that "from [May 30, 2010] forward your occurrences will count
3
against your attendance records." Coger Dep. 118-19, Ex. 16; Senters Dep. 47-48. On June 6,
2010, Coger signed the TRI attendance agreement. Coger Dep. 118- 19, Ex. 16; Senters Dep. 48.
At some point in 2010, the United Steelworkers Union ("Union") began
discussing possible representation with Regional Elite's agents at TRI. Coger Dep. 123-24,
131. Following a meeting which all available employees were required to attend in May, Senters
said that people who were interested in union information may stay, and those who did not
want union information could leave. Coger Dep. 138, 147-148.
Senters testified that she
explained to the employees that the Steelworkers wanted to organize them and handed out
information from Regional Elite regarding the organizing campaign. Senters Dep. 64-65.
Coger wanted the Union to represent her, Coger Dep. 123-24, 131, and she began
supporting the Union in May 2010. Coger Dep. 135-36. Coger considered herself the
mouthpiece for the Union at the Tri-Cities Airport. Coger Depo. 139-140. Coger communicated
with all Regional Elite employees at the facility regarding the Union. Coger Depo. 140-141.
Coger was actively and openly involved in soliciting individuals to support the Union organizing
efforts at the facility. Coger Dep. 138-139.
Coger also met some employees and Union
representatives at Carrabba's one night in May 2010 to discuss the Union. Coger Dep. 135-37,
139-40. Coger and one other Regional Elite employee, Stan Byrd, solicited employees to sign
cards supporting the Union. Coger Depo. 139. All but four of the Regional Elite employees at
the facility signed "cards" which expressed their desire to have Union representation. Coger
Depo. 137. Coger solicited and gathered cards as late as September. Coger Depo. 139. Coger
planned to attend a Union meeting in Minneapolis in early October. She publicly posted a notice
requesting shift trades for the dates of the meeting. Coger Depo. 137. However, she did not tell
Regional Elite that she was going to a Union meeting in October. Coger Dep. 138.
4
Coger testified that management told her only to "let them know immediately" if
employees were approached by the Union. Coger Dep. 127-28. Regional Elite employees were
instructed to inform management if they were contacted by the Union.1 Coger Depo. 127. Coger
gave Senters the business card of the Union organizer that contacted her at the beginning of the
organizing campaign. Coger Depo. 126.
Coger believes that Senters was the only one who knew she supported the Union. Coger
Dep. 151-54. Coger believes Senters knew about her support of the Union as early as May
2010. Coger Dep. 147-48, 183-84. Coger believes Senters knew of her support for the Union for
several reasons because (1) in May 2010 Senters told employees in a meeting they should stay if
they wanted to hear information about the Union and Coger remained in the meeting; (2) Coger
scheduled a shift trade so that she could attend a Union meeting in Minneapolis; and (3) Coger
would talk about the Union 10-15 feet outside of Senters's office. Coger Dep. 138, 156,
183. Coger is only speculating that Senters heard or saw her talking to colleagues about the
Union because it occurred outside her office. Coger Dep. 156. Senters testified that she only
heard "gossip" about which station employees might be "for" the Union. Senters Dep. 67. In
addition, Senters told Coger that a union “would limit her ability to do things.” Coger 150-151.
Senters also testified that she shared her feelings regarding her personal involvement in a union
when she worked at Kroger. Senters Dep 76-77.
Coger admitted that no one was “openly hostile” to her for her support of the Union.
Coger Dep. 155. No one in Regional Elite management ever confronted Coger regarding
her support for the Union. Coger Dep. 154. Again, Coger discussed the Union with Senters on
1
Coger claims that Regional Elite informed its employees that the Company would fold if the Union was voted in.
Coger Depo. p. 140; 145-146. Coger testified that she does not have the document, and she has been unable to
produce it through any other means. Coger Dep. 144-47. The defendant has raised admissibility issues regarding
this testimony.
5
only two occasions. Coger Dep. 152-53. In the first conversation, Coger claims that Senters told
her if the Union was voted in "it would limit her ability to what she can and cannot do" at the
station. Coger Dep. 150-51. Coger believed Senters's comment meant that Senters would not
have as much discretion under a union contract and that she would have to follow a collective
bargaining agreement. Coger Dep. 151. In the second conversation, Coger claims that Senters
told agents during a station meeting "those of you who are not interested in Union information
can go and those of you that are may stay." Coger Dep. 147-49. Coger did not leave the station
meeting after Senters made this announcement. Coger Dep. 147-49.
On June 3, 2010 Coger received half (.5) an occurrence for arriving to work four (4)
minutes late. Coger Dep. 168-69, Ex. 25. On July 11, 2010 Coger received another half (.5) an
occurrence for again being late to work by four (4) minutes. Coger Dep. 168-69, Ex. 25. On July
20, 2010 Coger received one (1) occurrence for being late to work by 57 minutes. Coger Dep.
168-69, Ex. 25. On July 21, 2010 Coger received one (1) occurrence for being late by 32
minutes. Coger Dep. 168-69, Ex. 25. On July 26 and 27, 2010 Coger received two (2)
occurrences for being absent two days without a doctor's note. Coger Dep. 168-69, Ex. 25. On
July 28, 2010, the day she returned to work, Coger received a verbal warning for accumulating
her fourth and fifth occurrences on July 26 and July 27, 2010. Coger Dep. 168- 69, Ex. 25.
Coger acknowledged receiving the verbal warning that same day, July 28, 2010. Coger Dep.
168-69, Ex. 25. Coger acknowledges she was absent or tardy on these days. Coger Dep. 16869. Coger took issue with the fact that it took Senters over a month and a half to first counsel her
regarding the attendance policy. Coger Dep. 169-70. Coger understood that she was not required
to be counseled under the attendance policy until her fourth occurrence. Coger Dep. 169-70. On
August 16, 2010 Coger received a written warning for her sixth occurrence (on August 11, 2010)
6
when she was 18 minutes late to work. Coger Dep. 170-71, Ex. 26. Coger does not dispute her
tardiness on August 11, 2010. Coger Dep. 170-71. On August 16, 2010 Coger incurred her
seventh and eighth occurrences for reporting to work two hours and sixteen minutes late. Coger
Dep. 172-75, Ex. 27. Coger was issued a final written warning for her attendance on August 17,
2010 in accordance with the policy. Coger Dep. 172-75, Ex. 27. Coger acknowledges that she
was tardy on August 16, 2010. Coger Dep. 172-75. 60. Coger thought it was "crap" that she
received two occurrences for arriving to work over two hours late since, had she known she
would, Coger would have just taken the whole day off and incurred only one occurrence. Coger
Dep. 173-75. On September 21, 2010 Coger was late to work by 27 minutes. Coger Dep. 17577, Ex. 28.
Senters did not make the decision to terminate Coger's employment; she
merely recommended it to her Regional Manager, J.W. Jones, who in turn approved it and
forwarded it to Regional Elite's People Department for approval. Senters Dep. 105-06. The
recommendation to terminate Coger's employment was reviewed and approved by Regional Elite
People Generalist Cory Knutson. Wright Dep. 21-22, 37-39, 47-48, Ex. 2 at Coger 001, 006007. Knutson approved the recommendation to discharge Coger and then forwarded it to People
Manager Carrie Wright for her review. Wright Dep. 21-22, 37-39, 47-48, Ex. 2 at Coger001,
006-007. Both Knutson and Wright reviewed all of the documents supporting the request and
confirmed Coger's attendance record and the station's adherence to the attendance policy. Wright
Dep. 21-22, 37-39, 47-48, Ex. 2 at Coger 001, 006-007. Wright approved Coger's termination
and only then was Coger's employment actually terminated (on September 27, 2010). Coger
Dep. 175-77, Ex. 28; Wright Dep. 60. Coger refused to sign the termination document and told
Senters that she would hear from her attorney. Coger Dep. 175-77. Regional Elite has an appeal
7
process where employees can ask management to review their termination, but Coger did not
utilize it. Coger Dep. 90; Wright Dep. 22-23.
Coger testified about Senters treating only two employees more favorably: Tyler Sanders
and Tim Miller. Coger Dep. 186-89. She believed that Sanders had been treated more favorably
under the attendance policy, and that Miller had been treated more favorably under the shift trade
policy. But Coger testified that she did not know how many attendance occurrences Sanders
received, and that she had not seen his personnel file. Coger Dep. 186-89. Moreover, Sanders
admitted that he was issued occurrences for his absences and tardiness. Sanders Dep. 26-29, Ex.
6 (SUMF, 72-73). Coger also knew of only one incident where Miller was allowed to trade
shifts. Coger Dep. 189-89. Any special treatment Miller received was likely due to Senters's and
Miller's personal relationship. Coger Dep. 188-89. Coger believes "if that had been me or, you
know, someone else, that probably wouldn't have flew." Coger Dep. 188-89. Coger was never
disciplined for not following the shift-trade policy. Coger Dep. 120-21. Furthermore, TRI agent
Stan Byrd stated he was not treated any differently for advocating for the Union. Byrd Decl. ¶¶
3-5.
Coger is not aware of the occurrence infraction status of any of her co-workers. Coger
Dep. 186-89. On October 17, 2010 Sanders was placed on a final written warning
for attendance. Sanders Dep. 26-29, Ex. 6. The only time that Sanders missed work and was not
issued an occurrence was when he missed scheduled days of work due to an on-the-job injury (an
authorized absence) between September 13 and October 13, 2010. Sanders Dep. 26-29, Ex.
6. Coger is not aware of any agent who received nine occurrences under Regional Elite policy
and was not discharged for it. Coger Dep. 186-89. Senters also discharged TRI agents Connie
Obriant and David Williamson for violating Regional Elite's attendance policy. Senters Dep.
8
49. Senters issued numerous warnings to other agents for reaching more than four
(4) occurrences in a rolling twelve month period. Senters Dep. 50.
II. SUMMARY JUDGMENT STANDARD
Summary judgment is proper where Athe pleadings, the discovery and disclosure
materials on file, and any affidavits show that there is no genuine issue of material fact and that
the movant is entitled to judgment as a matter of law.@ Fed. R. Civ. P. 56(c). In ruling on a
motion for summary judgment, the Court must view the facts contained in the record and all
inferences that can be drawn from those facts in the light most favorable to the non-moving
party. Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587 (1986); Nat=l
Satellite Sports, Inc. v. Eliadis, Inc., 253 F.3d 900, 907 (6th Cir. 2001). The Court cannot weigh
the evidence, judge the credibility of witnesses, or determine the truth of any matter in dispute.
Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249 (1986).
The moving party bears the initial burden of demonstrating that no genuine issue of
material fact exists. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). To refute such a
showing, the non-moving party must present some significant, probative evidence indicating the
necessity of a trial for resolving a material factual dispute. Id. at 322.
A mere scintilla of
evidence is not enough. Anderson, 477 U.S. at 252; McClain v. Ontario, Ltd., 244 F.3d 797, 800
(6th Cir. 2000). This Court=s role is limited to determining whether the case contains sufficient
evidence from which a jury could reasonably find for the non-moving party. Anderson, 477 U.S.
at 248-49; Nat=l Satellite Sports, 253 F.3d at 907. If the non-moving party fails to make a
sufficient showing on an essential element of its case with respect to which it has the burden of
proof, the moving party is entitled to summary judgment.
Celotex, 477 U.S. at 323. If this
Court concludes that a fair-minded jury could not return a verdict in favor of the non-moving
9
party based on the evidence presented, it may enter a summary judgment. Anderson, 477 U.S. at
251-52; Lansing Dairy, Inc. v. Espy, 39 F.3d 1339, 1347 (6th Cir. 1994).
The party opposing a Rule 56 motion may not simply rest on the mere allegations or
denials contained in the party=s pleadings. Anderson, 477 U.S. at 256. Instead, an opposing
party must affirmatively present competent evidence sufficient to establish a genuine issue of
material fact necessitating the trial of that issue. Id. Merely alleging that a factual dispute exists
cannot defeat a properly supported motion for summary judgment. Id. A genuine issue for trial
is not established by evidence that is Amerely colorable,@ or by factual disputes that are irrelevant
or unnecessary. Id. at 248-52.
III. ANALYSIS
First, the plaintiff alleges that she was terminated in violation of Section 2, Third and
Section 2, Fourth of the RLA. These claims are often referred to as “union animus” claims. To
establish a union animus claim, the plaintiff must show that (1) she engaged in protected activity;
(2) the company was aware of such activity; (3) the company harbored animus toward the
activity; and (4) the animus was a causal factor in the termination. See Int’l Bhd. of Teamsters v.
UPS Co., 447 F.3d 491 (6th Cir. 2006); Lebow v. American Trans Air, Inc., 86 F.3d 661, 666
(7th Cir. 1996) (stating the elements of a prima facie case for discrimination pursuant to RLA).
Here, the defendant conceded, for the purposes of the summary judgment motion, that the
first element is satisfied, i.e. that the plaintiff engaged in a protected activity. The second
element is whether the defendant was aware of such activity.
There exists direct and
circumstantial evidence that Senters knew about the plaintiff’s union activity. Senters directly
spoke with the plaintiff regarding the Union. Specifically, Senters told Coger that a union
“would limit her ability to do things.” Coger 150-151. Senters also testified that she shared her
10
feelings regarding her personal involvement in a union when she worked at Kroger. Senters Dep
76-77. In addition, Coger gave Senters the business card of the Union organizer that contacted
her at the beginning of the organizing campaign. Coger Depo. 126.
Moreover, there is circumstantial evidence that Senters knew of the plaintiff’s support for
the Union because in May 2010 Senters told employees in a meeting they should stay if they
wanted to hear information about the Union and Coger remained in the meeting. Also, Coger
scheduled a shift-trade so that she could attend a Union meeting in Minneapolis although there is
some dispute over whether Senters knew of the reason for the change. Coger would talk
about the Union 10-15 feet outside of Senters's office. Coger Dep. 138, 156, 183. Finally,
Senters testified that she only heard "gossip" about which station employees might be "for" the
Union. Senters Dep. 67.
All of this evidence is sufficient to withstand summary judgment on
this second element.
As to the third element, whether the company harbored animus toward the union activity,
there is no direct evidence of open hostility. However, there is a genuine issue of fact as to this
factor based on circumstantial evidence. When taking the facts in the light most favorable to the
plaintiff, there is evidence in the record that the defendant instructed employees not to talk to
Union representatives and to inform management if a Union representative attempted to contact
them. Also, after an apparently required company meeting, employees who were interested in
the Union were told they could stay to receive information. Although there is nothing overtly
discriminatory about this action, a jury could reasonable conclude that this was an attempt by the
defendant to identify union supporters or a way to pressure the interested employees not to attend
because they would clearly be identified. Senters also told the plaintiff that if the Union were to
organize, then it “would limit her ability to do things.” The defendant did not begin strictly
11
enforcing the attendance policy until near the same time as the union organization efforts.
Finally, the plaintiff was discharged for repeatedly violating the attendance policy shortly after
she had co-workers sign cards demonstrating their support for the Union.2
The last factor is whether the animus was a causal factor in the termination. Again,
considering the facts in the light most favorable to the plaintiff, a reasonable trier of fact could
infer such causation. Much of the evidence which supports the third factor likewise supports this
fourth factor.
The possible attempts by the defendant to identify the Union supporters is
circumstantial evidence of support. The fact that the attendance policy was not strictly enforced
until the union organizing efforts is further circumstantial evidence. Because this was the
conduct for which the plaintiff was terminated and because the termination was temporally
proximate to her efforts in soliciting co-workers to sign Union support cards, a reasonable trier of
fact could infer causation. For all of the reasons set forth above, there is a genuine issue of
material fact as to whether the plaintiff has a prima facie case as to her union animus claims. As
such, summary judgment in that regard is DENIED.
Second, this Court must address whether the Wright Line test applied in National Labor
Relations Act (“NLRA”) cases applies in RLA cases. See Wright Line, a Div. Of Wright Line,
Inc., 251 N.L.R.B. 1083 (N.L.R.B. 1980); see also Director v. Greenwich Collieries, 512 U.S.
267, 276-78 (1994) (discussing Wright Line); N.L.R.B. v. Transp. Mgmt. Corp., 462 U.S. 393,
395 (1983). Other courts have employed this burden-shifting framework in RLA cases. See
Amarsingh v. JetBlue Airways Corp., 409 Fed. Appx. 459 (2nd Cir. 2011); Lebow v. American
Trans Air, Inc., 86 F.3d 661, 666 (7th Cir. 1996); Roscello v. Southwest Airlines Co., 726 F.2d
217, 222-23 (5th Cir. 1984); Air Line Pilots Ass'n Int'l v. E. Air Lines, Inc., 863 F.2d 891, 893
2
There is enough circumstantial evidence contained in the record that this Court need not address the plaintiff’s
claim that the defendant distributed a memorandum indicating that the Company would fold if employees organized.
12
(D.C. Cir. 1988); see also Diaz v. Amerijet Int'l Inc., 872 F. Supp. 2d 1365 (S.D. Fla. 2012);
Calloway v. SkyWest Airlines, 179 LRRM 2750 (D. Utah 2006); Grosschmidt v. Chautauqua
Airlines, Inc., No. C85-1432-A, 1986 WL 10077, at *6 (N.D. Ohio April 11, 1986); and Beckett
v. Atlas Air, Inc., 968 F. Supp. 814 (E.D.N.Y. 1977). This Court finds the reasoning set forth in
those cases persuasive and will utilize the Wright Line test in this case.
Third, the Court must now apply the Wright Line test. According to Wright Line, the
employee must prove by a preponderance of the evidence that her protected conduct was a
substantial or motivating factor for the discharge. N.L.R.B. v. G&T Terminal Packaging Co.,
Inc., 246 F.3d 103, 116 (2d Cir. 2001). Once this burden is met, the employer can avoid liability
if it demonstrates by a preponderance of the evidence that it would have terminated the employee
absent the protected conduct. Id.
Although this Court has found that a reasonable trier of fact could infer a prima facie case
and even causation from the circumstantial evidence, this Court cannot find that the plaintiff’s
protected conduct was the motivating factor for the discharge because the evidence shows that
the defendant would have terminated her absent the protected conduct. Granted the timing of the
discharge is somewhat troubling; however, it is undisputed that the plaintiff clearly violated the
no-fault attendance policy. In addition, there is no evidence that any other union supporter, in
particular, Stan Byrd, was discriminated against. Furthermore, the evidence shows that the
attendance policy was implemented and tracked consistently and fairly. Every employee’s
attendance record was reset to zero occurrences prior to the “new” strict enforcement. All
employees were retrained on the policy and signed documentation indicating their understanding.
The plaintiff signed such a document. In sum, the plaintiff can point to no other instance of
discrimination and no other incident where another employee, who was not a union supporter,
13
was treated more favorably than herself. There is no genuine issue of material fact on this issue.
Accordingly, the defendant’s motion for summary judgment is GRANTED.
IV. CONCLUSION
For the reasons set forth above, the defendant’s motion is GRANTED. The case is,
therefore, dismissed on the merits.
ENTER:
s/J. RONNIE GREER
UNITED STATES DISTRICT JUDGE
14
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?