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Shafer v. Army & Air Force Exchange Service
Citations: 277 F.3d 788; 51 Fed. R. Serv. 3d 685; 2002 U.S. App. LEXIS 428; 82 Empl. Prac. Dec. (CCH) 41,003; 87 Fair Empl. Prac. Cas. (BNA) 1345; 2002 WL 2970Docket: 00-10854
Court: Court of Appeals for the Fifth Circuit; January 11, 2002; Federal Appellate Court
Original Court Document: View Document
Judith Ann Parks filed a Title VII discrimination and contempt action against the Army Air Force Exchange Service (AAFES), stemming from a previous class action lawsuit that identified sex discrimination against female employees hired after 1972. The district court had previously ruled in the class action that AAFES' policies had a disparate impact on these employees regarding promotions. Following this decision, Parks' individual claims were assigned to a Special Master, who recommended her retroactive promotion in 1988, which the court ordered AAFES to implement and prohibited any retaliation against her. In 1994, Parks accused AAFES of violating the 1988 order, leading to another referral to the Special Master. She also filed a separate suit alleging new discrimination and retaliation, which was merged with the original case. An extensive evidentiary hearing took place in 1996, but the Special Master failed to file the hearing transcripts with the district court. In 2000, the district court approved the Special Master's recommendations without having reviewed the transcripts, which were later reconstructed and incorporated into the record by court order. The Federal Rules of Civil Procedure stipulate that a court must accept a Special Master's findings unless deemed clearly erroneous, imposing a duty on the district court to review these findings independently. The court must affirmatively determine that the findings satisfy the clear error standard. Parties are entitled to a court review to assess whether findings are clearly erroneous, which includes examining all relevant evidence, potentially including complete hearing transcripts. In this instance, the district court adopted the Special Master’s recommendations without having received the hearing transcript or exhibits from the parties. The Special Master’s findings were based on conflicting narratives regarding Parks' departure from AAFES and unclear testimony about the AAFES promotion system. Given the complexity of Parks' claims, the district court could not adequately meet its obligations under Rule 53 without reviewing the hearing transcripts. The appellate court cannot review the Special Master’s proceedings directly; such a review must first occur at the district court level. Consequently, the district court's judgment is vacated, and the case is remanded for the necessary evaluation of the Special Master’s findings.