Megan Olsen v. Costco Wholesale Corporation

Summary

The United States District Court for the Eastern District of California denied Megan Olsen’s motion under Federal Rule of Civil Procedure 59(e) to reconsider summary judgment for Costco Wholesale Corporation. The court declined to award Costco its requested costs, citing the potential chilling effect of costs in employment discrimination actions, Olsen’s financial hardship, and the parties’ economic disparity. The court granted Costco’s request to seal certain personnel and job-change records but denied sealing of a limited query report.

Holdings

1. Reconsideration was not warranted because Plaintiff possessed the discovery before the court issued its summary-judgment decision and could have raised it before that decision.
2. Plaintiff did not identify a manifest error of law warranting reconsideration. The prior summary-judgment ruling appropriately concluded that no vacant position was shown to be available and that Plaintiff failed to present evidence that she could perform the essential functions of the identified RTV Clerk position.
3. The court declined to award Costco costs despite its status as the prevailing party.
4. The court granted the sealing request as to personnel records and job-change information but denied it as to the query report.

Questions Presented

1. Whether Plaintiff was entitled to reconsideration under Rule 59(e) based on evidence disclosed before the court decided the summary-judgment motion.
2. Whether Plaintiff demonstrated a manifest error of law in the court's prior summary-judgment ruling on reasonable accommodation, the interactive process, and disability discrimination claims.
3. Whether the court should exercise its discretion to deny the prevailing Defendant's requested costs under Rule 54(d)(1).
4. Whether Costco established compelling reasons to seal personnel records, job-change information, and a query report filed with the reconsideration motion.

Disposition

other