Hughes-Brown v. Campus Crest Group, LLC, 3:10-cv-00366

Plaintiff Hughes-Brown worked for Campus Crest from June 2008, alleging a sexually and racially hostile environment led by COO Brian Sharpe.
Plaintiff contends she was demoted and reassigned to administrative duties, while a less-qualified white male received higher pay for the same work.
She complained to HR and in-house counsel about the conduct and retaliation for her complaints, with limited action taken.
Hughes-Brown filed a Title VII discrimination and retaliation claim and an EEOC charge in October 2009, amended in October 2009 to include hostile environment and retaliation.
In May 2010 the EEOC issued a right-to-sue notice and Hughes-Brown filed a complaint in August 2010 seeking to consolidate with a related action (McCormack & McAuliffe v. Campus Crest).
The court denied consolidation, finding differences in parties, timing, and theories would cause juror confusion and prejudice outweighing any judicial economy.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 42(a) consolidation is proper	Hughes-Brown seeks consolidation for efficiency and common factual questions.	Consolidation would risk confusion and prejudice due to distinct plaintiffs and claims.	Consolidation denied; cases not sufficiently identical to justify consolidation.
Are there common questions of law or fact	Claims arise from a shared hostile environment framework against Campus Crest.	Disparate duties, timing, and additional claims undermine commonality.	Common questions exist but not to the extent required for consolidation.
Impact of differing employment roles and evidence needs	All plaintiffs faced hostile environment claims under Title VII.	Hughes-Brown's demotion and race-based disparate terms require different proof than others.	Differences in job roles and evidence support denying consolidation.
Effect on juror prejudice vs. judicial economy	Consolidation would save time and resources.	Consolidation would confuse jurors and prejudice defenses.	Prejudice and confusion outweigh any potential economy.

Harris v. L & L Wings, Inc., 132 F.3d 978 (4th Cir. 1997) (consolidation appropriate when cases are virtually identical and share defenses and witnesses)
Arnold v. Eastern Air Lines, 681 F.2d 186 (4th Cir. 1982) (weigh prejudice, confusion, and efficiency when consolidating actions)
Grayson v. K-Mart Corp., 849 F. Supp. 785 (N.D. Ga. 1994) (plaintiffs must present more than general theories of law for consolidation)
In re Cree, Inc., 219 F.R.D. 369 (M.D.N.C. 2003) (consider burden on witnesses and judicial resources in consolidation rulings)