What’s in a name?
Friday, June 14th, 2019
The law can be a strict, formalistic, unforgiving beast. It is with a certain amount of self-awareness that I note that much of what we do as attorneys is helping people to navigate the tricky seas of a legal claim. Given that degree of occasional harshness, I’ll take any opportunity to note decisions where a wronged worker is allowed to pursue their case despite the hurdles in their way.
In many cases, the identity of the party that you are trying to file a complaint against is not a mystery. This wasn’t exactly the case in Humberto Trujillo v. Rockledge Furniture LLC, a case which was recently decided in the Federal Seventh Circuit Court of Appeals. The details of Mr. Trujillo’s claim was, at its core, an employment discrimination claim which he sought to file first with the Equal Employment Opportunity Commission (“EEOC”) and then in civil court. However, the store where he was employed was not called “Rockledge Furniture LLC.” It was an Ashley Furniture HomeStore. Which, as it turns out, was owned by “Rockledge Furniture LLC.” Which is a company based out of Wisconsin associated with a corporation named “Ashley Furniture Industries, Inc.” And which was doing business in Illinois registered under the name “Ashley Furniture HomeStore – Rockledge.”
You can probably guess where this is going. In 2016, Mr. Trujillo filed an age discrimination and retaliation charge with the EEOC against his employer, giving the address and phone number of the store where he worked and naming them as Ashley Furniture HomeStore. Though a computer system glitch that would be somewhat comical if the consequences were not so serious, the EEOC ended up sending his complaint to “Hill County Holdings, LLC” which happens to be the Ashley Furniture HomeStore affiliate operating in Texas, of all places. Hill County Holdings, understandably, told the EEOC that they had no idea who Humberto Trujillo was. At this point Mr. Trujillo’s attorneys pointed out that the EEOC had contacted the wrong Ashley Furniture, and noted that Mr. Trujillo had provided the EEOC with the address of the store where Mr. Trujillo worked. His attorneys also gave the EEOC a copy of a paystub which clearly listed Rockledge Furniture LLC and even had the company’s Headquarter’s contact information on it. The EEOC, for reasons that the seventh circuit decision describes as a “mystery,” at this point promptly closed the claim and issued Mr. Trujillo a right to sue his employer-all without actually ever actually contacting Rockledge or Mr. Trujillo’s store.
When Mr. Trujillo filed his claim in court, then, Rockledge filed a motion to dismiss his claim because, they argued, Mr. Trujillo had not actually ever filed an underlying EEOC charge against them, nor were they ever made aware of the underlying EEOC charge. The district court granted their motion, effectively ending Mr. Trujillo’s claim.
Luckily, the appellate court was more sympathetic to Mr. Trujillo’s situation and reversed the dismissal. They point out in their decision that Mr. Trujillo gave a correct address for his place of employment in his original EEOC charge, and in fact got most of registered name correct: “Ashley Furniture HomeStore” vs. “Ashley Furniture HomeStore – Rockledge.” Further, regarding the problem of Rockledge genuinely not knowing about the claim prior to the lawsuit, the court points out that it was the job of the EEOC to contact the employer, and Mr. Trujillo gave them more than enough information to do so. It would make little sense to hold Mr. Trujillo responsible for the EEOC’s failure to act on that information. Better, the court rightly found, to give the parties a chance to work out their dispute rather than strangling the claim over a slightly mistaken name and a bit of mishandling on the part of the EEOC.
An eminently sensible decision, and good news both for MR. Trujillo and for workers generally.
-Attorney Travis Dunn