Rodolfo Quiles v. Union Pacific Railroad Company
4 F.4th 598
| 8th Cir. | 2021Background
- Quiles was hired by Union Pacific in Feb 2014 as a D-band General Manager and concurrently served in the Marine Corps Reserve; he deployed in May 2015.
- While Quiles was deployed, Union Pacific reorganized and eliminated all general-manager titles; it created a General Director role requiring five years of field experience and appointed Adelman to that role.
- When Quiles returned in Oct 2015 he was placed in a D-band Director position with the same pay and benefits but a different title, reporting to a D-band superior; Quiles viewed this as a demotion.
- Quiles sought internal remedy, became insubordinate, and Union Pacific terminated him in Mar 2016; Quiles sued under USERRA for failure to reemploy and related claims.
- The district court granted Quiles JMOL on the reemployment claim, denied Union Pacific’s JMOL, submitted remaining claims to a jury (which found for Union Pacific), and awarded Quiles some attorney fees; Union Pacific appealed.
- The Eighth Circuit reversed the district court’s grant of Quiles’s JMOL, reversed the fee award, and directed the district court to enter judgment for Union Pacific.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing / subject-matter jurisdiction | Quiles argued his USERRA claim gave him a cognizable injury and relief was available while litigation proceeded | Union Pacific argued that because Quiles received no damages or equitable relief the case lacked injury and thus jurisdiction | Court rejected Union Pacific’s challenge; Quiles had standing during litigation and lack of success does not defeat jurisdiction |
| District court’s grant of JMOL to Quiles on USERRA reemployment | Quiles argued Union Pacific failed to reemploy him in his escalator position after deployment | Union Pacific argued it reemployed Quiles consistent with the escalator principle given a bona fide reorganization and qualification requirements | Court held the district court erred in granting Quiles JMOL; a reasonable jury could find Union Pacific properly reemployed Quiles |
| Denial of Union Pacific’s JMOL | Quiles argued disputed facts supported the district court’s denial and the jury verdict | Union Pacific argued the evidence showed it lawfully placed Quiles given elimination of his prior role and his lack of required field experience | Court concluded district court should have granted Union Pacific JMOL and directed entry of judgment for Union Pacific (jury’s finding of termination for cause and undisputed reorg facts were dispositive) |
| Attorney fees under USERRA | Quiles claimed he was a prevailing party based on the district court’s JMOL and sought fees | Union Pacific argued Quiles was not a prevailing party because he obtained no final judgment or relief | Court held Quiles was not a prevailing party; fee award vacated |
Key Cases Cited
- Scudder v. Dolgencorp, 900 F.3d 1000 (8th Cir. 2018) (USERRA interpretation and scope)
- Milhauser v. Minco Prods., Inc., 701 F.3d 268 (8th Cir. 2012) (application of the escalator-position principle)
- Buckhannon Bd. & Care Home, Inc. v. W. Va. Dep’t of Health & Human Res., 532 U.S. 598 (U.S. 2001) (prevailing-party standard for fee awards)
- Mausolf v. Babbitt, 85 F.3d 1295 (8th Cir. 1996) (standing requirements: injury, causation, redressability)
- Duban v. Waverly Sales Co., 760 F.3d 832 (8th Cir. 2014) (standard of review on JMOL; drawing inferences for nonmoving party)
- Parke v. First Reliance Std. Life Ins. Co., 368 F.3d 999 (8th Cir. 2004) (abuse-of-discretion standard for fee awards)