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Ý¿-» îæïðó½ªóðïìïíóÍÎÞ Ü±½«³»²¬ èë Ú·´»¼ ðéñîéñïð п¹» ï ±º ë Arthur R. GoldbergAssistant Director, Federal Programs Branch U.S. Department of Justice, Civil Division20 Massachusetts Avenue, N.W.
Washington, DC 20530Tel. (202) 305-7920/Fax (202) 616-8470 PLAINTIFF’S RESPONSE TO
THE MOTION OF DAVID
SALGADO AND CHICANOS POR
The State of Arizona; and Janice K. Brewer, LA CAUSA, INC. TO
CONSOLIDATE
INTRODUCTION
The United States respectfully submits this memorandum in opposition to the motion by David Salgado and Chicanos Por La Causa, Inc. to consolidate the instant action with Salgado v. Brewer, No. CV-10-0951-PHX-SRB (D. Ariz.). Consolidation of the two cases is inappropriate because individualized issues present in the Salgado case but not the instant action would prejudice or delay the United States’ lawsuit.
ARGUMENT
The Federal Rules of Civil Procedure allow separate lawsuits to be consolidated where the “actions before the court involve a common question of law or fact.” Fed. R.
Ý¿-» îæïðó½ªóðïìïíóÍÎÞ Ü±½«³»²¬ èë Ú·´»¼ ðéñîéñïð п¹» î ±º ë Civ. P. 42(a). Although a district court has “broad discretion” in evaluating a motion to consolidate (Paxonet Communs., Inc. v. Transwitch Corp., 303 F. Supp. 2d 1027, 1028- 29 (N.D. Cal. 2003)), this Court has explained that “[c]onsolidation is inappropriate . . . if it leads to inefficiency, inconvenience, or unfair prejudice to a party.” See Glass v. Intel Corp., 2007 U.S. Dist. LEXIS 57666, at *11 (D. Ariz. 2007). Similarly, “consolidation may be inappropriate if individual issues predominate” or if the issues in one case will “confus[e]” the adjudication of another case. See Lewis v. City of Fresno, 2009 U.S. Dist.
LEXIS 57083, at *3-4 (E.D. Cal. 2009) (internal citations omitted). See also Campbell v. PriceWaterhouseCoopers, 2008 U.S. Dist. LEXIS 75756 (E.D. Cal. 2008) (“Factors to be weighed [in evaluating a motion to consolidate] include the risk of prejudice and Consolidation may also be rejected if one case presents an issue that need not be adjudicated in the other case. See, e.g., W. Watersheds Project v. United States Forest Serv., 2009 U.S. Dist. LEXIS 1359 (D. Idaho 2009) (rejecting consolidation because one of the cases involved a waiver issue that was not present in the other case, and because rejecting consolidation “keeps [the] case simple and avoids delay”). Thus, if the plaintiff in one case “rel[ies] on different legal theories to support their claims” than a plaintiff in the second case, consolidation may prove unduly prejudicial. Behrend v. Klein, 2006 U.S. Dist. LEXIS 68652 (E.D.N.Y. 2006).
This Court should reject the instant motion to consolidate because Salgado v. Brewer presents significantly different issues from the instant dispute. Defendants have moved to dismiss the Salgado claims for lack of standing – an issue that is not present in the United States’ lawsuit against Arizona. Although the United States does not offer any opinion on the merits of the standing issue in Salgado, the dispute itself creates a sufficient distinction between the cases as to recommend against consolidation. See, e.g., W. Watersheds Project v. United States Forest Serv., 2009 U.S. Dist. LEXIS 1359 (D.
Idaho 2009). Indeed, Plaintiffs have acknowledged that they hope to cure any potential defects as to standing in their own case by reference to other plaintiffs in other lawsuits.
Ý¿-» îæïðó½ªóðïìïíóÍÎÞ Ü±½«³»²¬ èë Ú·´»¼ ðéñîéñïð п¹» í ±º ë See Transcript of Oral Argument, July 15, 2010, at 23-24, Salgado v. Brewer, No. CV-10- 0951-PHX-SRB (D. Ariz.) (“If one plaintiff in any of these seven cases has standing, Your Honor, they all have standing. . . . [Plaintiffs] ask that you consider the issue of Additionally, although both disputes challenge the constitutionality of certain sections of S.B. 1070, the United States has challenged a larger portion of the statute than the Salgado plaintiffs – who have only challenged Sections 2, 3, and 6 of S.B. 1070 – and has sought to vindicate very different interests than those presented in Salgado. Whereas the United States has sought to prevent Arizona from interfering with its enforcement priorities, undermining foreign policy, and harassing lawfully present aliens, the Salgado preemption argument claims primarily that S.B. 1070 negates certain specific provisions of the INA. These different legal theories recommend against consolidation. See Behrend v. Klein, 2006 U.S. Dist. LEXIS 68652 (E.D.N.Y. 2006).
Consolidation will likewise delay the United States’ litigation. The Salgado plaintiffs have asked for a preliminary injunction pending a “trial on the merits.” See Transcript of Oral Argument, July 15, 2010, at 77, Salgado v. Brewer, No. CV-10-0951- PHX-SRB (D. Ariz.). Whereas the Salgado plaintiffs apparently plan to seek leave to conduct a trial, the United States’ lawsuit presents purely legal questions which should be resolved without a trial. Consolidation with Salgado would thereby prejudicially delay the instant litigation. See Glass v. Intel Corp., 2007 U.S. Dist. LEXIS 57666, at *11-12 (rejecting consolidation so as to avoid “unreasonable delay” in one of the actions).
Moreover, consolidation will not necessarily promote judicial efficiency.
Although the Salgado plaintiffs conclusorily claim that consolidation would “avoid duplication of effort, reduce legal fees and costs, and simplify the adjudication of the underlying dispute” (Motion at 2), the Salgado plaintiffs have not in any way explained how such judicial economy will arise. The Salgado plaintiffs and the United States have already fully briefed their respective motions for a preliminary injunction and have participated in oral argument on the same. Future briefing is ill suited to consolidated Ý¿-» îæïðó½ªóðïìïíóÍÎÞ Ü±½«³»²¬ èë Ú·´»¼ ðéñîéñïð п¹» ì ±º ë efforts because the United States has challenged different sections of the statute from the Salgado plaintiffs, has advanced different preemption arguments from the Salgado plaintiffs, and seeks to protect different interest from the Salgado plaintiffs.
“The moving party bears the burden of showing consolidation is appropriate.” See Lewis v. City of Fresno, 2009 U.S. Dist. LEXIS 57083, at *4. The Salgado plaintiffs have failed to meet this burden, having failed to establish what efficiencies would result from consolidation (beyond those already achieved from having all the related cases before the same judge), and having failed to address the individual issues involved in Salgado v. Brewer. See In re Consolidated Parlodel Litig., 182 F.R.D. 441, 447 (D.N.J.
1998) (“I conclude that the predominance of individual issues . . . prevent Plaintiffs from meeting their burden on this motion to consolidate under Rule 42.”). This Court should therefore deny the motion to consolidate.
CONCLUSION
For the foregoing reasons, the Court should deny the motion to consolidate the instant action with Salgado v. Brewer, No. CV-10-0951-PHX-SRB (D. Ariz.).
Arthur R. GoldbergAssistant Director, Federal Programs Branch Joshua Wilkenfeld (NY Bar #4440681)Varu Chilakamarri (NY Bar #4324299) U.S. Department of Justice, Civil Division20 Massachusetts Avenue, N.W.
Washington, DC 20530Tel. (202) 305-7920/Fax (202) 616-8470 joshua.i.wilkenfeld@usdoj.govAttorneys for the United States Ý¿-» îæïðó½ªóðïìïíóÍÎÞ Ü±½«³»²¬ èë Ú·´»¼ ðéñîéñïð п¹» ë ±º ë CERTIFICATE OF SERVICE
I hereby certify that on July 27, 2010, I electronically transmitted the attached document to the Clerk’s Office using the CM/ECF System for filing and transmittal of Notice of Electronic Filing to the CM/ECF registrants on record in this matter.

Source: http://www.researchsociety.org/Cases/10-CV-01413-SRB/85-00-20100727.pdf

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