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DAVID A. CIRACI; CARLA GROSJEAN; MEGAN L.
MORR; JOSEPH M. ADAMS,
Plaintiffs-Appellants,
v.
J.M. SMUCKER COMPANY,
Defendant-Appellee. |
No. 22-3462 |
Appeal from the United States District Court for the Northern District of Ohio at Akron.
No. 5:21-cv-02347—John R. Adams, District Judge.
Argued: January 26, 2023
Decided and Filed: March 14, 2023
Before: SUTTON, Chief Judge; CLAY and BUSH, Circuit Judges.
_________________________
OPINION
_________________________
SUTTON, Chief Judge. Four employees of the J.M. Smucker Company sought religious
exemptions from the company’s vaccine requirements. When the company refused, they filed
this free-exercise claim under the First Amendment against Smucker’s. Constitutional
guarantees conventionally apply only to entities that exercise sovereign power, such as federal,
state, or local governments, and, in some other instances, tribal governments. Smucker’s may be
a big company. But it is not a sovereign. Even so, did Smucker’s become a federal actor—did it
exercise sovereign power?—for purposes of this free-exercise claim when it sold products to the
federal government and when it imposed the vaccine mandate because the federal government
required it to do so as a federal contractor? No, as the district court correctly held. We affirm. |
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KATHRYN RODRIGUEZ,
Plaintiff-Appellant,
v.
HIRSHBERG ACCEPTANCE CORPORATION; MODERN
FINANCIAL SERVICES CORPORATION (20-2253),
Defendants-Appellees. |
Nos. 20-2184/2247/2253 |
Appeal from the United States District Court
for the Western District of Michigan at Grand Rapids.
No. 18-cv-00240—Janet T. Neff, District Judge;
No. 20-cv-00877—Hala Y. Jarbou, Chief District Judge.
Argued: November 1, 2022
Decided and Filed: March 14, 2023
Before: McKEAGUE, THAPAR, and READLER, Circuit Judges.
_________________________
OPINION
_________________________
CHAD A. READLER, Circuit Judge. District courts, it is broadly accepted, enjoy
tremendous freedom in managing their caseload. That flexibility stems in part from the fact that
no two district courts are the same. Nor do any two courts employ the same exact practices in
overseeing their dockets. Those practices can reflect more art than science, given the unique
demands each court faces. But at times, art must yield to science, so to speak. That is the case
with the Federal Rules of Civil Procedure. As an overarching goal, the Rules seek to promote
procedural uniformity across the federal courts. As a result, the conventions those Rules set out
may cede only so much to the whims of a particular district court. Sometimes, a district court
can deviate so far from the Rules that its practices amount to an abuse of discretion.
This is such a case. The district court utilized an “administrative closure” to suspend and
ultimately dismiss this suit. That practice comes from judicial fiat, not the Federal Rules of Civil
Procedure, which articulate different procedures for dispensing with a case. In this instance, the
district court’s deployment of local practices is irreconcilable with the requirements set forth in
the Rules. Accordingly, we reverse the district court and remand the case for further
consideration. |
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