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Medley v. Westpoint Stevens, Inc.
Citations: 162 F.R.D. 697; 1995 U.S. Dist. LEXIS 12142; 1995 WL 500268Docket: Civ. A. No. 95-A-127-S
Court: District Court, M.D. Alabama; August 18, 1995; Federal District Court
Tonia Medley filed a federal lawsuit on January 27, 1995, claiming discrimination under Title VII of the Civil Rights Act of 1964, specifically due to her pregnancy, after being discharged by her employer, WestPoint Stevens, Inc. WestPoint successfully moved for summary judgment on July 18, 1995, asserting that Medley was terminated for failing to report to work for four consecutive days without notifying the employer or requesting medical leave, a standard company policy. The court noted that while Medley established three elements of a prima facie discrimination case (pregnancy status, qualifications, and discharge), she failed to prove the fourth element—differential treatment compared to other employees. In her Motion to Reconsider, filed on July 28, 1995, Medley included an affidavit from her husband alleging that other employees had received extended medical leave without formal requests, which she argued supported her discrimination claim. The court analyzed the motion under Rule 59(e) of the Federal Rules of Civil Procedure, emphasizing that such motions are meant to correct clear errors and prevent manifest injustice, but are rarely granted. It highlighted that introducing new evidence in a reconsideration motion is generally not accepted unless the evidence was unavailable during the initial proceedings. Ultimately, the court denied Medley’s motion, reaffirming that she did not adequately establish her prima facie case and that her arguments could have been presented earlier. In Morgan v. Harris Trust, the court establishes that a party seeking reconsideration of a summary judgment must demonstrate that any new evidence was both recently discovered and could not have been obtained prior to the hearing. Evidence available during the summary judgment process cannot be introduced later in a motion to reconsider, nor can new arguments or evidence be presented that could have been submitted earlier. The court emphasizes fairness and judicial efficiency, noting that statements from plaintiffs that could have been included in the initial motion do not qualify as new evidence. In a related Florida case, the court denied a plaintiff's request to introduce additional evidence post-summary judgment, asserting that such evidence must have been available before the court's ruling. The court found the plaintiff's supplemental affidavit, which related to events from three years prior, did not constitute new evidence as it could have been presented earlier. Consequently, the motion to vacate or reconsider the summary judgment was denied, and the court refrained from addressing the defendant's arguments regarding the affidavit's compliance with procedural rules, determining that denying the plaintiff's motion would not cause manifest injustice.