Karna v. BP Corp. N. Am.
| Decision Date | 31 March 2014 |
| Docket Number | Civil Action No. 4:12–cv–0101. |
| Citation | 11 F.Supp.3d 809 |
| Parties | Vinay K. KARNA, Plaintiff, v. BP CORPORATION NORTH AMERICA, INC., Defendant. |
| Court | U.S. District Court — Southern District of Texas |
John Christopher Juravich, Attorney at Law, Houston, TX, for Plaintiff.
Richard Austin Schwartz, Schwartz Junell et al., Houston, TX, for Defendant.
Before the Court in this Fair Labor Standards Act (“FLSA”) case is Plaintiff Vinay K. Karna's Motion for a New Trial and/or Reconsideration under Rule 59. (“Plaintiff's Motion”; Doc. No. 92.) Mr. Karna seeks a new trial, arguing that 1) the Court's ruling on the parties' summary judgment motions, Doc. No. 55, erroneously deprived him of trial on his quantum meruit and wrongful termination claims; and 2) the jury's verdict that he was a computer professional exempt from the protections of the FLSA was against the weight of the evidence and should be overturned. After reviewing the evidence and argument presented by the Parties, as well as their submissions and the relevant law, the Court is not persuaded that a new trial is warranted. Consequently, Mr. Karna's Motion is DENIED.
Mr. Karna is a former employee of Defendant BP Corporation North America, Incorporated (“BP”). He brought this action against his former employer, alleging violations of the FLSA, 29 U.S.C. §§ 201 –219, as well as several Texas state law claims: breach of contract, quantum meruit, negligent misrepresentation, fraudulent misrepresentation, promissory estoppel, and wrongful discharge. Pl.'s First Am. Orig. Pet. (“Petition”; Doc. No. 1.) The facts of the case are set out more fully in the Court's summary judgment order, and are incorporated here by reference. See Mem. & Order, Mar. 19, 2013, 2013 WL 1155485. (Doc. No. 55.)
At summary judgment, the Court dismissed Mr. Karma's negligent misrepresentation, fraudulent misrepresentation, promissory estoppel, and wrongful discharge claims and determined that his quantum meruit claim was preempted by the FLSA. Doc. No. 55. Mr. Karna later dismissed his breach of contract claim. Doc. Nos. 67–68. Mr. Karna's remaining claims were then tried before a jury. The jury was asked to decide (1) whether Mr. Karna was exempt under the FLSA's computer professional exemption during the relevant time period; (2) whether BP's failure to pay overtime compensation was willful; and (3) the amount of Mr. Karna's damages. After hearing the evidence, the jury concluded that Mr. Karna's employment satisfied the requirements of the FLSA's computer professional exemption; consequently, the jury did not address the other questions. Thereafter, the Court entered final judgment in accordance with the jury's verdict and its summary judgment decision. Doc. No. 90. The pending motion followed.
Though the Federal Rules of Civil Procedure do not themselves specifically provide for a motion for reconsideration, such motions nevertheless are entertained under the Rules. They are generally analyzed under the standards for a motion to alter or amend a judgment under Rule 59(e) or a motion for relief from a judgment or order under Rule 60(b). See Hamilton Plaintiffs v. Williams Plaintiffs, 147 F.3d 367, 371 n. 10 (5th Cir.1998). Here, Mr. Karna seeks reconsideration under Rule 59. A motion under Rule 59(e) must “clearly establish either a manifest error of law or fact or must present newly discovered evidence.” Ross v. Marshall, 426 F.3d 745, 763 (5th Cir.2005) (quoting Simon v. United States, 891 F.2d 1154, 1159 (5th Cir.1990) (internal quotation marks omitted)). Such motions Id. In considering a motion for reconsideration, a court “must strike the proper balance between two competing imperatives: (1) finality, and (2) the need to render just decisions on the basis of all the facts.” Edward H. Bohlin Co. v. Banning Co., 6 F.3d 350, 355 (5th Cir.1993). While a district court has “considerable discretion” to grant or deny a motion under Rule 59(e), id., the Fifth Circuit cautions that reconsideration under Rule 59(e) is an extraordinary remedy that courts should use sparingly. Templet v. HydroChem Inc., 367 F.3d 473, 479 (5th Cir.2004).
Federal Rule of Civil Procedure 59 also states that a court may, on motion, grant a new jury trial “for any reason for which a new trial has heretofore been granted in an action at law in federal court.” Fed.R.Civ.P. 59(a)(1)(A). A court therefore may grant a new trial if it finds that the verdict is against the weight of the evidence, the damages awarded are excessive, the trial was unfair, or prejudicial error was committed in its course. Smith v. Transworld Drilling Co., 773 F.2d 610, 613 (5th Cir.1985). A new trial may also be granted when the jury's inconsistent verdict cannot be reconciled. See Crossland v. Canteen Corp., 711 F.2d 714, 726 (5th Cir.1983). In short, courts are to assess “the fairness of the trial and the reliability of the jury's verdict.” Seidman v. Am. Airlines, Inc., 923 F.2d 1134, 1140 (5th Cir.1991). When a party moves for a new trial on evidentiary grounds, a new trial should not be granted unless “the verdict is against the great weight of the evidence.” Pryor v. Trane Co., 138 F.3d 1024, 1026 (5th Cir.1998). The decision to grant a new trial lies within the discretion of the court. Shows v. Jamison Bedding, Inc., 671 F.2d 927, 930 (5th Cir.1982).
Mr. Karna brings two challenges to the Court's summary judgment decision and attacks the jury's verdict on one ground. Regarding summary judgment, he argues that the Court erred in ruling that his state law quantum meruit claim for unpaid compensation is preempted by the FLSA. Consequently, he asserts, when the jury found that he was exempt from the FLSA's wage and hour protections, he was unable to recover even the hourly wages BP had promised him. He also claims that the Court ignored evidence establishing his wrongful termination claim, and thus prevented the jury from deciding that issue as well. In addition to these, Mr. Karna challenges as against the weight of the evidence the jury's verdict that he was a computer professional exempt from the FLSA's minimum wage and maximum hour provisions.
Mr. Karna seeks reconsideration of the Court's ruling that his quantum meruit claim is preempted by the FLSA. See Mem. & Order at 36–39, Mar. 19, 2013. (Doc. No. 55.) He argues that the Court's preemption ruling and the jury's FLSA exemption finding combined to prevent him from recovering even the base hourly compensation promised him for the hours he claims to have worked, whether over or under the inapplicable statutory maximum. Importantly, Mr. Karna asserts that he is not seeking the overtime premium compensation promised by Section 7 of the FLSA. See Pl. Karna's Reply Def. BP's Resp. Mot. New Trial and/or Recons. under Rule 59 at 2–3 (“Plaintiff's Reply”; Doc. No. 94).
Mr. Karna first cites Freeman v. City of Mobile, Alabama, 146 F.3d 1292 (11th Cir.1998), in support of his argument against preemption. Freeman stands for the proposition that some state-law claims, such as those arising under a state statute or local ordinance which provides certain public sector employees overtime protections stronger than those of the FLSA, may not necessarily be preempted by the FLSA: Id. at 1298 (internal citations omitted).
In response, BP correctly argues that, in Texas, a quantum meruit claim is available only in the absence of a contract. See Mem. & Order at 36, Mar. 19, 2013 (Doc. No. 55) (citing U.S. Quest Ltd. v. Kimmons, 228 F.3d 399, 406 (5th Cir.2000) ). Freeman, however, solely concerns contracts giving certain employees “rights to overtime compensation beyond those required by the FLSA.” BP reminds the Court that Mr. Karna has repeatedly asserted that he was not employed under a contract. See, e.g., Pl. Karna's Resp. Def. BP's Mot. Summ. J. at 29 (“Plaintiff's MSJ Response”; Doc. No. 35) (“[T]here are no express contracts between the parties covering the unpaid services that Karna rendered for BP.”). Freeman is thus inapposite here.
Mr. Karna also argues that, because he could still prevail on his quantum meruit claim, even though he can no longer succeed on his FLSA claim (because he was found to be an exempt employee), the claims are not duplicative, making preemption inappropriate. In support, Mr. Karna cites Diallo v. Alo Enterprises Corporation, No. 12–3762, 2013 WL 3772827 (D.N.J. July 17, 2013). There, the court was considering whether to allow Mr. Diallo to amend his complaint to add state law breach of contract claims in addition to his FLSA overtime and minimum wage claims. The question was whether the FLSA preempted the state law claims, but the central issue was Mr. Diallo's employment status: was he an employee within the meaning of the FLSA or an independent contractor? The court reasoned that the fact that employment status was at issue argued against preemption because, if Mr. Diallo was found to be an employee, he could proceed with his FLSA claims. On the other hand, if he was found to be an independent contractor, he could proceed with his state law breach of contract claims.
Here, BP is correct that Mr. Karna's status as an employee was not at issue in deciding the preemption question; the Court had already determined that he was an employee during the relevant period. Mem. & Order at 24, Mar. 19, 2013. (Doc. No. 55.) While BP finds that...
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