Searching over 5,500,000 cases.

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Jackson v. Teamsters Local Union 922

United States District Court, District of Columbia

September 1, 2016

RALPH JACKSON, et al., Plaintiffs,
TEAMSTERS LOCAL UNION 922, et al, Defendants.



         As any buyer of a new car knows, driving off the lot typically triggers a feeling of buyer's remorse. In other words, once we know there is an opportunity lost by a decision we make, we often feel post-decision regret. Plaintiffs, eight former employees of Giant Food, LLC, who have brought a "hybrid" claim under the Labor Management Relations Act alleging wrongdoing by both Giant and their Unions, appear to suffer from a serious case of buyer's remorse with regard to the severance package they accepted when the grocery-store company laid them off. They insist that had they known that their decision to opt for severance pay meant they forfeited the right to be placed on a recall list, which might have afforded them an opportunity to be rehired within six months of their termination, they would not have accepted such payments. Giant maintains that the choice posed by the severance package was clear, and that Plaintiffs are precluded from suing the company by the releases they signed.

         In bringing this suit, Plaintiffs contend that they are not bound by such releases because Giant only induced them to sign through material misrepresentations. As causes of action, they allege that the two Unions of which they were members, Local 730 and Local 922, failed to adequately discharge their duty of fair representation in negotiating the terms of the severance and release, and that Giant's termination of them and subsequent recall of other employees violated its collective-bargaining agreements with the Unions. In an earlier Opinion, the Court ruled that these two claims are interrelated, constituting one "hybrid" claim against both Giant and the Unions, all three of whom are Defendants in this suit.

         Defendants reject Plaintiffs' narrative and, asserting that the material facts at issue are undisputed, have separately moved for summary judgment. Concluding that Giant made no material misrepresentations related to Plaintiffs' release agreements and that their waiver of claims is therefore valid, the Court will grant the company's Motion. In addition, as Plaintiffs' hybrid claim is deficient, the Court will also grant the Unions' Motion, putting an end to this long-running conflict arising from Plaintiffs' choice.

         I. Background

         While the Court well knows that facts on summary judgment should be considered in the light most favorable to the non-movant, it also notes that, pursuant to Federal Rule of Civil Procedure 56(c), parties "asserting that a fact cannot be or is genuinely disputed must support the assertion by . . . citing to particular parts of materials in the record, " and the Court "need consider only the cited materials, [though] it may consider others in the record." Fed.R.Civ.P. 56(c)(1)(A), (c)(3). In this case, Defendants have submitted a 54-page Joint Statement of Facts, Plaintiffs have responded with a 137-page Response, and both sides have each submitted more than 60 exhibits. See Def. JSOF (ECF No. 130-7); PL Resp. to JSOF (ECF No. 141-1). Plaintiffs' filings, in addition to being voluminous, are riddled with typographical errors and incomplete sentences, frequently confuse argument with fact, and often fail to identify precise record citations to support their claims. It is not the Court's duty to mine the record for every relevant evidentiary item. See Pottery. District of Columbia, 558 F.3d 542, 553 (D.C. Cir. 2009) (Williams, J., concurring). Where "a party fails to properly support an assertion of fact or fails to properly address another party's assertion of fact. . ., the court may . . . consider the fact undisputed." Fed.R.Civ.P. 56(e)(1); see also LCvR 7(h)(1) (explaining that Court may assume that nonmoving party "admitted" facts it failed to "controvert" in its response or opposition). In other words, the Court will decline the invitation to fill in the literal blanks left by Plaintiffs' briefing. See, e.g., PI. Resp. to JSOF, ¶ 104 ("Plaintiffs further incorporate by reference then-responses in response to Defendants allegations in paragraphs, as if fully pled herein."), ¶ 130 ("See Ex____"). With these principles in mind, the Court recites the facts relevant to its disposition of Defendants'Motions for Summary Judgment.

         A. Parties and Setting

         Plaintiffs in this case are eight former employees of Giant, which operates a chain of grocery stores located in Maryland, Virginia, Delaware, and the District of Columbia. See PI. Resp. to JSOF, ¶ 1. While employed by Giant, Plaintiffs were members of one of two unions, Local 922 or Local 730 ("the Unions"). Id., ¶ 2. Until 2011, Giant's retail stores were supported by two distribution centers located in Jessup, Maryland: one for "fresh" groceries and the other for "dry" groceries. Id., ¶ 6. The fresh-foods center, including a recycling facility, was operated entirely by Giant, but the dry-goods compound was only partially operated by Giant; the dry-goods recycling facility was run by the company, but the dry-goods warehouse was run by a subsidiary of C&S Wholesale Company. Id., ¶¶7-8, 15. All of the Plaintiffs worked at one of the two recycling facilities. Id., ¶ 9.

         In previous years, Giant had operated a variety of facilities in support of its stores -including its own dairy, bakery, and the like - but at the time of the events at issue, the company was focused more on the operation of its retail grocery stores and, in streamlining its operations, reallocated or laid off workers. Id., ¶ 16. In addition, in June 2012, C&S closed the dry-goods warehouse it operated in Jessup, Maryland, and relocated those operations to Pennsylvania, leading to a number of layoffs, including some members of Local 730. Id. ¶ 19. The parties agree that Giant learned of that planned closure in April 2012 and made some efforts to prepare for those layoffs, though they dispute precisely what actions were taken and when, id, ¶¶ 20-24; those disputes, however, are irrelevant to Defendants' Motions.

         In a memorandum dated April 26, 2012, and addressed to the entire Giant Distribution Team, Giant's Vice President of Distribution Operations, Mike Scott, informed the Team of the dry-goods-warehouse closure and indicated that "Giant was still assessing the impact of C&S's decision." Id. ¶26. This memorandum was posted in some employee break rooms. Id. Giant ultimately concluded that, after the C&S closure, "it would be more efficient to operate only one recycling facility instead of two." Id. ¶ 29 (citing Def. Exh. 12 (ECF No. 132-2) (Deposition of Billye Pounds, Giant Senior Manager of Human Resources) at 46:3-16). Because "multiple people" had been doing the "same work" at the two separate facilities, Giant expected that after their consolidation, it would not require as many employees. See Id. ¶ 32; Pounds Dep. at 55:10-56:10. The parties disagree about how Giant arrived at that expectation, whether its belief in the reduced need for employees was reasonable, and other such details, but Plaintiffs point to no testimony indicating that Giant did not "believe that the consolidation of the two warehouses would . .. mean that there was going to be less work for employees to do." Pounds Dep. at 55:13-15.

         B. Negotiation and Termination

         In late May and early June of 2012, Giant met with the leaders of Local 730 and Local 922 to discuss the effects of the facilities' consolidation -what the parties refer to as "effects bargaining." See PI. Resp. to JSOF, ¶¶ 34-46. Ritchie Brooks, President of Local 730, and Ferline Buie, President of Local 922, agreed that the two Unions would jointly negotiate with Giant during the effects bargaining. Id. ¶¶ 39, 46. At least one meeting between Buie and Giant was attended by five of the Plaintiffs. Id. ¶ 43.

         The Unions sought to convince Giant that the layoffs were not necessary, the number of laid-off employees should be fewer than the company's predictions, and Giant should engage in a $50, 000 voluntary buyout. Id. ¶¶ 49-51. The Unions succeeded in bargaining down the number of laid-off employees but not on their other demands. Id. ¶ 50. The Unions then requested severance pay for the affected employees or, in the alternative, "recall rights, " meaning the right to be placed on a list for potential rehire, based on seniority, following termination of employment. Id. ¶ 51. As to severance, the Unions asked Giant to provide two weeks of severance pay for each year of employment with the company, but Giant agreed to only one week per year of service. Id. ¶52. As to recall, the Unions asked that those employees who decided not to accept the severance package would have recall rights for one year. Id. ¶ 53. Giant and the Unions disputed whether each Union's Collective Bargaining Agreement with the Company already gave Union members recall rights, and Plaintiffs and Defendants continue to dispute what the CBAs required. Id. ¶¶ 54-57.

         Ultimately, the Unions and Giant agreed to a severance package under which affected employees would have the option either to receive up to eight weeks of severance pay, depending on their years of service but with a minimum of two weeks'pay, or instead to be placed on the recall list for six months. Id. ¶ 58. If they chose the latter option, they would still lose then-jobs, but would be eligible for rehire if Giant recalled any employees. The company agreed to reduce its number of layoffs to eight employees from Local 730 and twelve employees from Local 922. Id. ¶ 81. This agreement was later memorialized in two Memoranda of Understanding. See Def. Exh. 33 (ECF No. 133-13) (Local 922 MOU), 34 (ECF No. 133-14) (Local 730 MOU).

         During the effects bargaining, leadership of Local 730 and Local 922 had requested that the Unions, rather than Giant, be permitted to inform their members about the layoff, and Giant acquiesced. Id. ¶62; see also Def. Exh. 1 (ECF No. 131-1) (Deposition of Michael Scott, Giant Director of Warehousing) at 112:6-9. The Unions held these meetings from the beginning to the middle of June 2012. Id. ¶¶ 63-64. What was and was not said at those meetings is the source of some dispute, but the parties agree that representatives from Giant's Human Resources department and Distribution Services division attended, Id. ¶ 64, and that Union members were informed about the impending layoffs and severance package that had been negotiated on then-behalf with Giant. Id. ¶¶ 65, 74. The parties do not agree whether the Union leaders told Union members that, should they choose to decline the severance package, they would be placed on a recall list for up to six months. Id. In addition, information was provided to the employees who would be laid off to help them find new employment. Id. ¶ 67.

         At the request of Union leaders, Kelli Hall, Giant's Human Resources Manager, or her associate met individually with each of the twenty affected employees for approximately ten minutes each and provided them with copies of the Separation and Release Agreement they would need to sign if they chose to receive severance pay. Id. ¶¶ 87-90. Although Plaintiffs maintain that they did not understand the terms of the Agreement, Hall maintains that she read the separate Acknowledgement of Receipt of Separation and Release Agreement out loud to each of them and gave them copies of both documents, informed them that they had forty-five days in which to determine whether or not to sign it, encouraged them to consult with an attorney before signing it, and explained that, as required by the Older Workers Benefit Protection Act of 1990, employees had seven days after signing the Agreement in which to revoke it. Id., ¶ 92. She states that she explained that they would receive the severance pay within two weeks if they decided to sign the Agreement. Li After meeting with Hall, all Plaintiffs then signed the Acknowledgement, which set forth in writing this information. See Declaration of Kelli Hall, Exh. l(ECFNo. 130-4) (Plaintiffs' Signed Acknowledgements). The Acknowledgement also explained that the terminations had been determined pursuant to the seniority process in the Collective Bargaining Agreements and that employees should not sign and return the Agreement any earlier than three days before their last day of work. Id. The Agreement itself contained two provisions of special relevance to this litigation. The first is a paragraph entitled "Rehire" telling employees that by signing the Agreement, they "hereby agree not to knowingly seek or accept employment, whether directly or indirectly, with the Company ... or any of its operating companies or affiliates. You further agree that your execution of this Agreement is good and sufficient cause for the Company and/or its affiliates to reject any application you may make for employment or re-employment." Def. Exh. 2 (ECF No. 130-5) (Plaintiffs' Signed Agreements), ¶ 10. The second is a "Complete Release of Claims" paragraph explaining that employees

fully release, waive and forever discharge the Company . . . from any and all administrative claims, actions, suits, ... or liabilities of any nature . . ., whether known or unknown, arising prior to the Effective Date of this Agreement, including, but not limited to . . . all claims arising in law or equity or any claims arising under [a variety of federal and state statutory and common-law causes of action] .... You expressly agree and understand that this General Release means that you are releasing the Released Parties from all claims, whether known or unknown, . . . and whether or not the claims arise out of your employment with or termination of employment from the Company ....

Id., ¶ 3; see also Id. ¶ 4 ("Pursuit of Released Claims").

         All of the Plaintiffs signed the Agreements. Id. They agree that they had the opportunity to review the Agreement prior to signing it, though they maintain that they did not understand all of it. See PI. Resp. to JSOF, ¶ 110. Only one of the twenty laid-off employees opted not to sign the Agreement. Id. ¶ 108; see also Hall Decl., ¶ 17 (explaining that Frank Manieri told her he wanted to be placed on the recall list, and she told him that he should not sign the Agreement if he wanted to preserve the option of being recalled). The parties do not agree about what, if any, advice the Unions gave the employees about whether to sign the Agreements. See, e.g., PI. Resp. to JSOF, ¶¶ 111-12. No Plaintiff revoked or attempted to revoke her Agreement within seven days of signing it, and all Plaintiffs received their severance payments in accordance with the terms of their Agreements. Id. ¶¶ 114-15.

         On June 29, 2012, a massive storm known as a "derecho" hit the Washington metropolitan area, resulting in the loss of power to more than seventy of Giant's stores in the region. Id. ¶ 119. While the parties disagree about the impact of the storm on the Jessup facility's operations, Id. ¶¶ 120-21, it is undisputed that Giant chose to recall - first on a temporary basis and then permanently - three employees on July 4 and then hired twelve additional temporary employees in the days afterward. Id. ¶¶ 123-25. Plaintiffs maintain that Giant knew or should have known that the July 4th period would be a busy time, requiring additional workers, but Giant insists that it had no plans to recall or hire new workers prior to the derecho. Id. ¶¶ 123-26. Neither the eight Plaintiffs nor any of the other employees who signed the Agreements were among the recalled employees. Id. ¶ 127.

         C. Grievances, NLRB Charge, and Litigation

         In early July, Plaintiffs learned of some recalls. Id. ¶ 128. On August 16, 2012, members of Local 730, including Plaintiffs Tiffany Cherry, Christopher Mundell, and Sharron Foster, filed a "group grievance" with their Union complaining that their layoffs violated the Local 730 CBA. Id. ¶ 137. On the same day, members of Local 922, including Plaintiffs Donna Ward, Donchez Coates, Linda Mathis, William Christopher, and Ralph Jackson, also filed a "group grievance" with their Union raising the same complaint with regard to their CBA. Id. ¶ 138. A joint letter from both Unions was also sent on Plaintiffs' behalf to Giant's Human Resources department, accusing the company of improperly laying off Plaintiffs and requesting that the Company meet with them to resolve the grievance. Id. ¶ 139. The parties "vigorously" dispute whether the grievances filed against the Unions were timely and whether they were handled properly by the Unions, see, e.g., Id. ¶ 144, but neither Union processed the grievance to arbitration. Id. ¶¶ 146, 149. After receiving the grievances from the Unions, Giant denied the grievance of the Local 730 Plaintiffs by letter dated August 26, 2012, and the Local 922 Plaintiffs' grievance by letter dated August 29, 2012. Id. ¶¶ 144-48.

         On November 17, 2012, those Plaintiffs, through counsel, together filed three unfair-labor-practice charges with the National Labor Relations Board: one each against the Unions and one against Giant. Id. ¶ 152; see also Def. Exh. 45-46 (ECF No. 134-5, -6) (NLRB Charges). In their charges against the Unions, Plaintiffs claimed that Local 730 and Local 922 breached then-duty of fair representation vis-a-vis their termination and severance package; in their charge against Giant, Plaintiffs claimed the company "unlawfully" terminated their employment by inducing them through threats and coercion to sign the Separation and Release Agreements. See PI. Resp. to JSOF, ¶¶ 153-154. The NLRB Regional Office then conducted an investigation into the charges, Id. ¶ 156, which included interviewing six of the eight Plaintiffs. Id. ¶ 157.

         By letters dated January 31, 2013, the NLRB Regional Director, Wayne Gold, dismissed the charges against the Unions. See Def. Exh. 56-57 (ECF No. 134-16, -17) (Letters Dismissing Local 730 & Local 922 Charges) ("The investigation failed to reveal any evidence that employees were coerced into signing severance agreements. Rather, the evidence established that the Union simply informed employees of their options regarding severance."). Gold similarly dismissed the charge against Giant on the same day. See Def. Exh. 55 (ECF No. 134-15) (Letter Dismissing Giant Charge) ("The evidence obtained during the investigation established the Employer notified the employees' collective-bargaining representative of its decision to conduct the layoff. The Employer then bargained over the effects of the layoff with [that] representative. The employees were selected for layoff by order of seniority; and, they were provided with two options, (1) sign a severance agreement and waive .. . recall rights or (2) accept six months of recall rights. . .. Your allegation that the employees were threatened and coerced into signing the agreements also lacks evidentiary support.").

         Plaintiffs, unsurprisingly, appealed the Regional Director's dismissals to the NLRB's Office of Appeals. See Declaration of Ritchie Brooks, Exh. 8 (ECF No. 134-18) (Feb. 19, 2013, NLRB Appeal Acknowledgment) atl. On April 17, 2013, the NLRB Office of Appeals affirmed the Regional Director's dismissals of Plaintiffs' three charges, "substantially for the reasons in the Regional Director's letters of January 31, 2013." Id. at 3 (Apr. 17, 2013, NLRB Denial Letter).

         Shortly after Plaintiffs filed their NLRB Charges - but before those charges could be adjudicated - they filed suit in this Court against Giant and the Unions. See Complaint (ECF No. 1) (filed Dec. 27, 2012). The Complaint asserted six causes of action and sought monetary damages to compensate for lost wages, benefits, and emotional distress; reinstatement to their positions at Giant; attorney fees and costs; pre-judgment interest; and punitive damages. Id. at 7-16. With leave of court, Plaintiffs subsequently filed a 68-page Amended Complaint that asserted eight causes of action: breach of the duty of fair representation by the Unions (Counts I and II) and six counts against Giant, including breach of contract (Count III), "misrepresentation" (Count IV), fraud and constructive fraud (Counts V and VI), "detrimental reliance" (Count VII), and retaliation (Count VIII). See Amended Complaint (ECF No. 39). Defendants then moved to dismiss the Amended Complaint and alternatively sought summary judgment. See ECF Nos. 40-42.

         On February 12, 2014, this Court issued an Order granting in part and denying in part Defendants'motions. See ECF No. 53. In an accompanying Memorandum Opinion, the Court dismissed all of Plaintiffs' claims against Giant except for one: breach of contract. Jackson v. Teamsters Local Union 922, 991 F.Supp.2d 71, 86 (D.D.C. 2014). It further concluded that the breach-of-contract cause of action was in fact only viable as a claim under section 301 of the Labor Management Relations Act, and so should proceed under that statute. Id. at 81. The Court also held that it was premature to enforce the waiver of claims against Giant in the Separation and Release Agreements given that discovery had not yet fully fleshed out the circumstances surrounding those releases. Id. at 82-83.

         The Court then examined Plaintiffs' § 301 claim against Giant and their breach-of-duty-of-fair-representation claims against the Unions and concluded that these did not stand alone, but were, in fact, pled as a "hybrid section-301/fair-representation suit against both Giant and then-Unions." Id. at 81. As this hybrid claim was sufficiently pled to defeat a motion to dismiss, the Court permitted that sole cause of action to proceed against all three Defendants. Id. The parties next traveled through the discovery phase, during which they had a number of substantial disagreements over deposition testimony and expert witnesses. See Jackson v. Teamsters Local Union 922, 310 F.R.D. 179 (D.D.C. 2015) (striking portions of employees' errata sheets that made substantive changes or contradictions to prior deposition testimony); Jackson v. Teamsters Local Union 922, No. 12-2065, 2015 WL 11023790 (D.D.C. Oct. 26, 2015) (denying Plaintiffs' motion to reconsider Court's prior ruling on errata sheets); Jackson v. Teamsters Local Union 922, 312 F.R.D. 235 (D.D.C. 2015) (denying Plaintiffs' motion for leave to supplement expert reports). Eventually, Defendants each moved for summary judgment. See ECFNos. 128 (Local 922 MSJ), 129 (Local 730 MSJ), 130 (Giant MSJ). Those Motions are now ripe.

         II. Legal Standard

         Summary judgment may be granted if "the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law." Fed.R.Civ.P. 56(a); see also Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 247-48 (1986); Holcomb v. Powell, 433 F.3d 889, 895 (D.C. Cir. 2006). A fact is "material" if it is capable of affecting the substantive outcome of the litigation. See Liberty Lobby, 477 U.S. at 248; Holcomb, 433 F.3dat 895. A dispute is "genuine" if the evidence is such that a reasonable jury could return a verdict for the nonmoving party. See Scott v. Harris, 550 U.S. 372, 380 (2007); Liberty Lobby, 477 U.S. at 248; Holcomb, 433 F.3d at 895. "A party asserting that a fact cannot be or is genuinely disputed must support the assertion" by "citing to particular parts of materials in the record" or "showing that the materials cited do not establish the absence or presence of a genuine dispute, or that an adverse party cannot produce admissible evidence to support the fact." Fed.R.Civ.P. 56(c)(1).

         When a motion for summary judgment is under consideration, "[t]he evidence of the non-movant is to be believed, and all justifiable inferences are to be drawn in his favor." Liberty Lobby, 477 U.S. at 255; see also Mastro v. PEPCO, 447 F.3d 843, 850 (D.C. Cir. 2006); Aka v. Wash. Hosp. Or., 156 F.3d 1284, 1288 (D.C. Cir. 1998) (en banc). On a motion for summary judgment, the Court must "eschew making credibility determinations or weighing the evidence." Czekalski v. Peters, 475 F.3d 360, 363 (D.C. Cir. 2007).

         The nonmoving party's opposition, however, must consist of more than mere unsupported allegations or denials and must be supported by affidavits, declarations, or other competent evidence, setting forth specific facts showing that there is a genuine issue for trial. See Fed.R.Civ.P. 56(e); Celotex Corp. v. Catrett, 477 U.S. 317, 324 (1986). The nonmovant is required to provide evidence that would permit a reasonable jury to find in his favor. See Laningham v. U.S. Navy, 813 F.2d 1236, 1242 (D.C. Cir. 1987).

         III. Analysis

         Plaintiffs' "hybrid" section-301/fair-representation claim is composed of two parts: A claim against Giant for breach of its collective-bargaining agreements (CBA) and a claim against the Unions for breach of their duty of fair representation. See Cephas v. MVM, Inc., 520 F.3d 480, 485 (D.C. Cir. 2008) (citing DelCostello v. Int'l Bhd. Of Teamsters, 462 U.S. 151, 164-65 & n.14 (1983)). Because these components are "intertwined, " Jackson I, 991 F.Supp.2d at 81, Plaintiffs must succeed on both in order to prevail.

         In seeking summary judgment, Giant first contends that by signing Separation and Release Agreements, Plaintiffs have expressly waived their right to assert that the company violated the CBAs. Should its waiver argument fail to persuade, Giant also maintains that it did not breach the CBAs and that the Unions did not breach their duty of fair representation. The Unions similarly argue that Plaintiffs cannot succeed on either prong of their hybrid claim.

         The Court first finds that the Agreements are valid and thus release Giant from all claims Plaintiffs raise against the company. It next turns to the question of whether, as Plaintiffs assert, they may nevertheless bring a stand-alone claim against the Unions and the viability of such a claim.

         A. Waiver of Claims Against Giant

         Giant's first line of defense is its waiver argument: It insists that Plaintiffs waived then-right to bring any claim relating to their termination of employment with Giant, including any breach-of-CBA or hybrid claim, when they signed their Separation and Release Agreements with the company in June 2012.

         The Agreements, offered to employees "considered for separation pursuant to the number of positions available and the seniority process established in the Collective Bargaining Agreements, " Acknowledgements at 1, required that employees, in exchange for severance pay, "fully release, waive, and forever discharge the Company, [and] all affiliated or related companies .. . from any and all administrative claims, actions, suits, debts, demands, damages, claims, judgments, or liabilities of any nature, including costs and attorneys' fees, whether known or unknown, arising prior to the Effective Date of this Agreement." Agreement, ¶ 3. The Agreement expressly noted that this "General Release" applied "whether or not the claims ar[o]seout of your employment with or termination of employment from" Giant. Id.

         These terms, Giant insists, clearly cover the breach-of-CBA claim, which is based on the company's layoffs and recalls that Plaintiffs believe violated the CBA. The Agreements were Dated: June 28 or 29, 2012, depending on the Plaintiff, and their effective dates were eight days after Plaintiffs signed them. See id., ¶ 12(g). As the layoffs occurred on June 30, 2012, see Id. ΒΆ 1, predating the effective dates of the Agreements, Defendants believe any breach claims are waived. Plaintiffs do not dispute that if the waivers are valId. they are out of luck with respect to their suit against Giant. Instead, they rejoin that they were induced to sign the ...

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.