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U.S. Well Services, Inc. v. Scott Easom, et al.

Paid petition · United States Court of Appeals for the Fifth Circuit, No. 21-20202 · judgment June 15, 2022


Certiorari denied · November 14, 2022
Pre-decision estimate: 2% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Question presented

The Worker Adjustment and Retraining Notification (“WARN”) Act, 29 U.S.C. § 2101 et seq., generally requires employers to provide sixty days’ notice prior to a mass layoff or plant closing. However, the WARN Act contains an exception to the sixty-day notice requirement “if the plant closing or mass layoff is due to any form of natural disaster, such as a flood, earthquake, or the drought currently ravaging the farmlands of the United States.” 29 U.S.C. § 2102(b)(2)(B). This case presents two questions which were each decided differently by the district court and the court of appeals:

  1. Does COVID-19 qualify as a natural disaster under the WARN Act’s natural disaster exception, 29 U.S.C. § 2102(b)(2)(B)?

  2. What causal connection is required to trigger the WARN Act’s natural disaster exception, which applies when a plant closing or mass layoff is due to any form of natural disaster?

Counsel of record

For petitioner
David Matthew Korn
Phelps Dunbar LLP

For respondent
Gabriel Assaad
McDonald Worley

Case

Conference history
Distributed for 1 conference

Proceedings

  1. Nov 14 2022
    Petition DENIED.
  2. Oct 25 2022
    DISTRIBUTED for Conference of 11/10/2022.
  3. Oct 19 2022
    Waiver of right of respondent Scott Easom, et al. to respond filed.
  4. Oct 05 2022
    Petition for a writ of certiorari filed. (Response due November 10, 2022)