Court Opinions: 10th Circuit Court of Appeals Opinion for May 1

The 10th Circuit Court of Appeals

Editor’s Note: Law Week Colorado edits court opinion summaries for style and, when necessary, length.

Copeland, et al. v. C.A.A.I.R., et al.

Christian Alcoholics and Addicts in Recovery, based in Jay, Oklahoma, advertises itself as a residential addiction recovery program that uses a program of work training, counseling Narcotics Anonymous and Alcoholics Anonymous classes, life skill courses, weekly Bible study and church attendance. 

Many of CAAIR’s participants come to it through the criminal justice system, including by way of Oklahoma’s drug courts. As part of what it describes as its “work-based” rehabilitative work, CAAIR requires participants to perform work at nearby “work providers,” or facilities that partner with CAAIR. Simmons Foods, Inc. and Simmons Pet Food, Inc., which operate multiple poultry processing plants in Oklahoma, Missouri and Arkansas, is a work provider for CAAIR.

CAAIR participants aren’t paid to work at Simmons and other work providers. CAAIR participants agree that they’re clients and not employees, they won’t be paid, they may be discharged for failing to complete their work and they’re free to leave at any time but may face criminal justice consequences. 

The plaintiff-appellants in this appeal are 53 former state-court criminal defendants. Each participated in the program and worked at a Simmons plant. Briefings imply that a state court ordered each of them to complete the CAAIR program, usually in lieu of a portion of incarceration. 

In October 2017, four of the plaintiffs filed a punitive class complaint against CAAIR, Simmons and several CAAIR officials. They asserted 15 causes of action, alleging that CAAIR and Simmons violated the Fair Labor Standards Act, the Racketeer Influenced and Corrupt Organizations Act, trafficking laws and minimum wage laws. 

The plaintiffs alleged CAAIR failed to provide treatment and services and instead exploited their unpaid labor to enrich Simmons and Cair executives, including by forcing them to conduct dangerous work with no pay and preventing some plaintiffs from accessing medical treatments. 

Simmons moved to dismiss for failure to state a claim and failure to join the state of Oklahoma as a necessary and indispensable party. The district court granted in part and denied in part Simmons’ motion. The defendants then jointly moved to dismiss the four named plaintiffs for lack of subject matter jurisdiction pursuant to the Rooker-Feldman doctrine, which derives from Rooker v. Fidelity Trust Co. and District of Columbia Court of Appeals v. Feldman.

The district court granted the motion to dismiss for lack of subject matter jurisdiction for the named defendants, then on the same day, the court entered judgment “for the Defendants and against the Plaintiffs,” dismissing the claims of all the plaintiffs. 

The plaintiffs filed a Rule 59(e) motion to vacate, alter and amend the judgment, arguing the court erred because it dismissed the entire action, the court’s order constituted a nearly verbatim incorporation of the defendants’ motion and the court failed to consider the plaintiffs’ arguments and authorities. The court denied the motion and the plaintiffs appealed. 

A 10th Circuit Court of Appeals panel out of Tulsa, Oklahoma, reversed the district court’s order dismissing the named plaintiffs’ claims, remanded the case with instructions to the court to vacate in full its judgment and to conduct further proceedings consistent with the order and judgment.

Previous articleExpert Opinion: Multifamily and Commercial Real Estate Law Update
Next articleColorado Public Defenders Join May Day Rally


Please enter your comment!
Please enter your name here