The U.S. Court of Appeals for the Fifth Circuit issued a per curiam opinion Wednesday affirming the dismissal of an employment case against Clean Harbors Deer Park, L.L.C., marking the end of a legal dispute that involved multiple defendants and complex employment issues at a Texas hazardous waste facility.
In *Carmon v. Clean Harbors Deer Park*, the Fifth Circuit affirmed the U.S. District Court for the Southern District of Texas's grant of three separate motions to dismiss filed by the defendants. The appeals court also upheld the district court's denial of plaintiff Patsy E. Carmon's motion to set aside the final judgment and her motion for a new trial.
The case involved four defendants: Clean Harbors Deer Park, L.L.C., individual defendant Daniel Tauriello, the International Brotherhood of Teamsters Local 988, and Claude Horton. Clean Harbors operates a hazardous waste incineration facility where Carmon worked for more than two decades.
According to the court documents, Carmon began her employment with Clean Harbors in May 1996. As an employee of the facility, she was covered by a collective bargaining agreement between Clean Harbors and the International Brotherhood of Teamsters Local 988 labor union.
The case has a complex procedural history involving previous litigation. After three to four years of employment, Carmon and other employees filed a lawsuit alleging racial discrimination against Clean Harbors. That earlier case resulted in a settlement in 2003, though the specific terms of the settlement were not detailed in the Fifth Circuit's opinion.
The current litigation appears to stem from subsequent events during Carmon's employment at the facility. However, the Fifth Circuit's brief per curiam opinion did not elaborate on the specific claims that Carmon raised against the defendants in this case. The court noted that it was taking the facts alleged in Carmon's complaint as true for purposes of the appeal, which is standard practice when reviewing motions to dismiss.
The district court granted motions to dismiss filed by all defendants, effectively ending the case at the pleading stage. When a court grants a motion to dismiss, it typically means the plaintiff failed to state a claim upon which relief can be granted, either because the allegations were legally insufficient or because the plaintiff lacked standing to bring certain claims.
After the district court entered its final judgment dismissing the case, Carmon filed post-judgment motions seeking relief. She moved to set aside the final judgment and also filed a motion for a new trial. Both motions were denied by the district court, leading to her appeal to the Fifth Circuit.
The Fifth Circuit's opinion was designated as unpublished, meaning it will not be included in the official reporter and has limited precedential value under Fifth Circuit rules. The court issued a per curiam opinion, indicating that all three judges on the panel - Circuit Judges Richman, Higginson, and Oldham - agreed with the result without any individual judge authoring a separate opinion.
The brief nature of the Fifth Circuit's opinion suggests the court found the district court's rulings to be clearly correct on the law and facts presented. Appeals courts typically issue longer, more detailed opinions when cases present novel legal questions or when the lower court's reasoning requires extensive analysis.
The case illustrates the challenges that employment law plaintiffs face in federal court, particularly when bringing claims against multiple defendants with potentially different legal relationships to the workplace dispute. The involvement of both the employer and the union as defendants suggests the case may have involved issues related to the collective bargaining agreement or the union's duty of fair representation.
Clean Harbors Deer Park operates in a highly regulated industry involving hazardous waste management, which often subjects employers to additional federal and state oversight beyond typical employment regulations. The facility's workforce being represented by the Teamsters union also adds layers of complexity to employment disputes, as unionized employees must often navigate both federal employment law and labor law protections.
For Carmon, the Fifth Circuit's affirmance represents the conclusion of her federal court litigation. The appeals court's decision to affirm on all issues means she was unsuccessful in convincing the court that either the original dismissals were improper or that she was entitled to post-judgment relief.
The case was docketed as No. 24-40706 in the Fifth Circuit and originated from case No. 4:24-CV-1899 in the Southern District of Texas. The timing suggests the district court proceedings moved relatively quickly, with the case filed and resolved within the same calendar year before reaching the appeals court in 2025.