Paine Snider v. L-3 Communications Vertex Aerospace, LLC, No. 16-60731 (5th Cir. 2019)
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After Courtney Paine Snider filed suit against L-3 under Title VII of the Equal Rights Act of 1964, L-3 asserted counterclaims against Paine Snider and also brought suit against Womble Carlyle Sandridge & Rice, LLP, and Charles A. Edwards.
The Fifth Circuit held that the district court did not err in granting summary judgment on statute of limitations grounds on L-3's claims that Edwards provided Paine Snider with legal assistance and that the Womble firm failed to disclose that legal assistance; the district court did not err in dismissing Paine Snider's Title VII claims as a sanction for misconduct; and affirmed the district court's dismissal of these claims. However, the court held that the district court erred in granting summary judgment with respect to L-3's claims regarding the legal assistance Edwards provided another L-3 employee and Paine Snider's alleged misappropriation of confidential client documents. Therefore, summary judgment on statute of limitations grounds was improper where reasonable minds could differ as to whether the statute of limitations had run on those claims. The court reversed as to these claims. The court also reversed the district court's dismissal of L-3's claims with respect to the allegations that Paine Snider misappropriated confidential client documents and remanded as to that claim.
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