Williams v. BHI Energy I Power Services LLC

U.S. District Court, District of Minnesota

Williams v. BHI Energy I Power Services LLC

Trial Court Opinion

                UNITED STATES DISTRICT COURT                             
                    DISTRICT OF MINNESOTA                                


Marilyn Williams,                    Case No. 21-cv-1186 (KMM/DTS)       

               Plaintiff,                                                

v.                                          ORDER                        

BHI Energy I Power Services LLC,                                         

               Defendant.                                                


    Plaintiff Marilyn Williams (“Williams”) brought an employment discrimination 
action  against  her  former  employer  Defendant  BHI  Energy  I  Power  Services  LLC 
(“BHI”)  under  the  Minnesota  Drug  and  Alcohol  Testing  in  the  Workplace  Act 
(“DATWA”).  [Compl., ECF No. 1].  While employed by BHI as a payroll specialist, 
Ms. Williams was randomly selected for a drug test, failed the test, and was fired that 
same day.  [Id. ¶¶ 1–2, 5].  On August 24, 2023, the Court concluded that Ms. Williams’s 
DATWA claims against BHI were not preempted by federal law, and that BHI is liable 
for  violating  subdivision  6,  subdivision  10(a),  and  subdivision  10(b)  of  
Minn. Stat. § 181.953
.  [Summ. J. Order, ECF No. 134].                                
    BHI  now  moves the  Court  to  certify  three  questions  for  interlocutory  appeal.  
[Mot. to Certify Interlocutory Appeal, ECF No. 145].  The first is whether federal fitness-
for-duty regulations apply to contractors of nuclear licensees.  The second question is 
whether  field  preemption  applies  to  DATWA  with  respect  to  contractors  of  nuclear 
licensees in the face of Nuclear Regulatory Commission (“NRC”) regulations.  Lastly, 
BHI  questions  whether  conflict  preemption  applies  to  DATWA  under  these 
circumstances.    However,  BHI  has  failed  to  satisfy  the  three  elements  required  for 

certification of interlocutory appeal under 
28 U.S.C. § 1292
(b).  For the reasons stated 
below, BHI’s Motion for Certification is DENIED.                          
                         BACKGROUND                                      
    Ms.  Williams  brought  this  action  against  her  former  employer,  BHI,  for 
terminating her immediately upon learning that her drug test came back positive for THC, 
without providing her with an opportunity to explain or appeal the test results.  [Compl. 

¶¶ 2,  5].    When  notifying  Williams of  her  termination,  BHI  told  her it  had  a “zero 
tolerance” policy for positive drug tests, and, in its termination paperwork, BHI indicated 
that Williams’s was terminated for “fail[ing] a random drug test by the client.”  [Id. ¶ 6]. 
    Williams brought a state law claim against BHI for violating section 181.953 of 
DATWA for not giving her written notice of her right to explain the positive test, as well 

as the ability to identify non-illicit substances that may have impacted the test results as 
required under subdivision 6(b); and terminating her based on her initial positive drug 
test  in  violation  of  subdivision  10(a),  without  providing  her  with  an  opportunity  to 
participate in drug counseling or rehabilitation in violation of subdivision 10(b).  
Minn. Stat. § 181.953
, subds. 6(b), 10(a) & 10(b).  Following extensive litigation and discovery, 

Ms. Williams moved for partial summary judgment on BHI’s liability.  [Pl.’s Mot. for 
Partial Summ. J., ECF No. 102].  BHI also moved for summary judgment, arguing that 
Ms. William’s DATWA claim against her former employer was preempted by federal 

                               2                                         
law, specifically, the Atomic Energy Act.  [Def.’s Mot. for Summ. J., ECF No. 108].  The 
Court  granted  partial  summary  judgment  to  Ms. Williams,  finding  BHI  liable  for 

violating the three previously referenced subdivisions of § 181.953.  [Summ. J. Order].  
As  for  BHI,  the  Court  denied  its  motion  for  summary  judgment,  ruling  that  Ms. 
Williams’s DATWA claims against BHI were not preempted by federal law.  BHI now 
moves the Court to certify three questions for interlocutory appeal to the Eighth Circuit. 
                          DISCUSSION                                     

 I.   Standard of Review                                                 
    Interlocutory appeals in the federal system are generally disfavored.  See Firestone 
Tire & Rubber Co. v. Risjord, 
449 U.S. 368, 374
 (1981) (Ordinarily, unless the appeal 
falls within a “narrow exception,” a party must await a final judgment on the merits to 
file  an  appeal).    Frequent  use  of  §  1292(b)  requests  would  be  incompatible  with 
Congress’ intention to keep the federal courts’ final judgment rule in place and save 

interlocutory review for exceptional circumstances.  See Caterpillar v. Lewis, 
519 U.S. 61, 74
 (1996) (internal quotations omitted).  “It has long been the policy of courts to 
discourage piece-meal appeals because most often such appeals often result in additional 
burdens on both the court and the litigants.”  Union Cnty., Iowa v. Piper Jaffray & Co., 
525 F.3d 643, 646
 (8th Cir. 2008) (cleaned up).  Someone seeking interlocutory-appeal 

certification “bears the heavy burden of demonstrating that the case is an exceptional one 
in which immediate appeal is warranted.”  White v. Nix, 
43 F.3d 374, 376
 (8th Cir. 1994).  
To certify a ruling for mid-litigation appeal, a “district court must be of the opinion that 

                               3                                         
(1) the order involves a controlling question of law; (2) there is substantial ground for 
difference  of  opinion;  and  (3) certification  will  materially  advance  the  ultimate 

termination of the litigation.”  White, 
43 F.3d at 377
 (quotation omitted).  If any of these 
factors are unmet, interlocutory appeal is inappropriate.  Although the Court finds BHI is 
lacking as to all three factors, it fails the most clearly on questions two and three. 
 II.  Analysis                                                           
    A. Controlling Question of Law                                       
    The  first  element  in  assessing  whether  a  question  should  be  certified  for 

interlocutory appeal under § 1292(b) is that it involves a controlling question of law.  
28 U.S.C. § 1292
(b).  “A question of law is controlling if reversal of the district court’s order 
would terminate the action, or even if its resolution is quite likely to affect the further 
course  of  litigation.”    Varela  v.  State  Farm  Mut.  Auto.  Ins.  Co.,  Civil  No.  22-970 
(JRT/DTS), 
2023 WL 5021182
, at *3 (D. Minn. Aug. 7, 2023) (quotation omitted).   

    An issue is a question of law for purposes of § 1292(b) if it is not a matter for the 
trial court’s discretion.  White, 
43 F.3d at 377
.  That is, it cannot be a mixed question of 
law and fact.  See Fenton v. Farmers Ins. Exch., Civil No. 07-4864 (JRT/FLN), 
2010 WL 1006523
, at *2 (D. Minn. Mar. 16, 2010) (“In order for the Court to certify an order for 
an interlocutory appeal, there must be a controlling question of law, not merely a question 

of fact.”).  This means that “only pure questions of law may be certified for interlocutory 
appeal.”    Minnesota  ex  rel.  N.  Pac.  Ctr.,  Inc.  v.  BNSF  Ry.  Co.,  Civil  No.  08-6385 
(PAM/LIB), 
2010 WL 11537448
, at *2 (D. Minn. Sept. 30, 2010) (internal quotation 

                               4                                         
marks  omitted).    “Mixed  questions  of  law  and  fact  are  inappropriate  for  such  a 
proceeding.”  
Id.
                                                         

    On  its  face,  whether  federal  regulation  preempts  Williams’s  DATWA  claim 
appears to be a purely legal question.  However, in this case, the Court engaged in 
extensive consideration of the relevant facts, rendering the inquiry not one of “pure law.”  
See Varela, 
2023 WL 5021182
, at *3 (“While it is true that the resolution of this issue 
depends in part on the Court’s interpretation of the . . . policy, which is a matter of law, 
whether [Plaintiff] adequately pled a . . . claim requires application of the legal question 

to the facts of this specific case, which is not a matter of ‘pure law.’”).  In several 
respects, the Court analyzed the summary judgment factual record to reach its preemption 
decisions.  Most critically, the Court addressed the relationship between Xcel Energy (a 
nuclear licensee) and BHI (a contractor) to reach its conclusion that BHI was not directly 
covered by the NRC’s fitness-for-duty regulations.  [ECF No. 134 at 19–23].  The Court 

also carefully examined the record regarding both Xcel’s own procedures for drug tests in 
contrast to BHI’s, and what happened in this case.  [Id. at 23–26].  As such, BHI has 
failed  to  establish  that  the  questions  at  issue  are  purely  legal  as  contemplated  by  
§ 1292(b).                                                                
    B. Substantial Grounds for Difference of Opinion                     

    More importantly, the Court finds that BHI fails to make a sufficient showing as to 
the  second  factor  of  the  interlocutory  appeal  test.    There  is  substantial  ground  for 
difference of opinion when the party asking for interlocutory appeal has identified “a 

                               5                                         
sufficient  number  of  conflicting  and contradictory  opinions  [that]  provide  substantial 
ground  for  disagreement.”    White,  
43 F.3d at 378
  (internal  quotations  omitted).  

“However, substantial ground for difference of opinion does not exist merely because 
there is a dearth of cases.”  
Id.
 (citing Fed. Deposit Ins. Corp. v. First Nat’l Bank of 
Waukesha, Wis., 
604 F. Supp. 616, 620
 (E.D. Wis. 1985)).                  
    Here, the Court disagrees that there exists a substantial ground for difference of 
opinion with respect to the preemption questions raised by BHI in its motion.  Although 
the Court candidly observed places at which there was less guiding authority than usual 

in its opinion, its analysis was firmly grounded in an extensive examination of case law.  
Indeed,  BHI  points  to  no  aspects  of  the  Court’s  decision  that  are  contradicted  by 
authority,  binding  or  otherwise,  and  cites  no  authority  that  the  Court  disregarded  or 
misunderstood.  The simple reality that this case is complex or that some issues required 
close consideration simply does not satisfy the showing required for an interlocutory 

appeal.                                                                   
    C. Materially Advance the Termination of the Litigation              
    The  final  element  in  assessing  whether  a  question  should  be  certified  for 
interlocutory appeal under requires the party seeking certification of the appeal to show 
that an immediate appeal may materially advance the ultimate termination of litigation.  

28 U.S.C. § 1292
(b).  The Court may find that the third element for interlocutory appeal 
is met “if there would be a great amount of time and expense required to proceed with 
litigation  in  comparison  with  the  time  and  expense  of  staying  the  proceedings  and 

                               6                                         
pursuing an immediate appeal.”  Fenton, 
2010 WL 1006523
, at *2.  It is as to this factor 
that BHI makes the weakest showing of all.                                

    Here, the Court finds that BHI has not met their burden of demonstrating that an 
immediate appeal will save any real time or expense.  At this stage, only a damages trial 
remains.  A motion to dismiss, full discovery, and summary judgment have already been 
completed.  Very little is left to be done, so there is minimal efficiency in having an 
appeal now as opposed to following the damages finding and entry of judgment.  Given 
the procedural stage of this litigation, this case is not one of the unique situations where 

the rarely used tool of interlocutory appeal should be utilized.          
                    CONCLUSION and ORDER                                 
    Because  BHI  failed  to  satisfy  the  three  elements  required  under  
28 U.S.C. § 1292
(b) to certify its three questions for interlocutory appeal of the Court’s August 24, 
2023, Order, the Court denies BHI’s Motion for Certification.  Based on the foregoing 

analysis and all the files, records and proceedings herein, IT IS HEREBY ORDERED 
that Defendant BHI Energy I Power Services LLC’s Motion to Certify Interlocutory 
Appeal, [ECF No. 145], is DENIED.                                         


Date: March 7, 2024              s/Katherine Menendez                     
                                Katherine Menendez                       
                                United States District Court             


                               7                                         

Trial Court Opinion

                UNITED STATES DISTRICT COURT                             
                    DISTRICT OF MINNESOTA                                


Marilyn Williams,                    Case No. 21-cv-1186 (KMM/DTS)       

               Plaintiff,                                                

v.                                          ORDER                        

BHI Energy I Power Services LLC,                                         

               Defendant.                                                


    Plaintiff Marilyn Williams (“Williams”) brought an employment discrimination 
action  against  her  former  employer  Defendant  BHI  Energy  I  Power  Services  LLC 
(“BHI”)  under  the  Minnesota  Drug  and  Alcohol  Testing  in  the  Workplace  Act 
(“DATWA”).  [Compl., ECF No. 1].  While employed by BHI as a payroll specialist, 
Ms. Williams was randomly selected for a drug test, failed the test, and was fired that 
same day.  [Id. ¶¶ 1–2, 5].  On August 24, 2023, the Court concluded that Ms. Williams’s 
DATWA claims against BHI were not preempted by federal law, and that BHI is liable 
for  violating  subdivision  6,  subdivision  10(a),  and  subdivision  10(b)  of  
Minn. Stat. § 181.953
.  [Summ. J. Order, ECF No. 134].                                
    BHI  now  moves the  Court  to  certify  three  questions  for  interlocutory  appeal.  
[Mot. to Certify Interlocutory Appeal, ECF No. 145].  The first is whether federal fitness-
for-duty regulations apply to contractors of nuclear licensees.  The second question is 
whether  field  preemption  applies  to  DATWA  with  respect  to  contractors  of  nuclear 
licensees in the face of Nuclear Regulatory Commission (“NRC”) regulations.  Lastly, 
BHI  questions  whether  conflict  preemption  applies  to  DATWA  under  these 
circumstances.    However,  BHI  has  failed  to  satisfy  the  three  elements  required  for 

certification of interlocutory appeal under 
28 U.S.C. § 1292
(b).  For the reasons stated 
below, BHI’s Motion for Certification is DENIED.                          
                         BACKGROUND                                      
    Ms.  Williams  brought  this  action  against  her  former  employer,  BHI,  for 
terminating her immediately upon learning that her drug test came back positive for THC, 
without providing her with an opportunity to explain or appeal the test results.  [Compl. 

¶¶ 2,  5].    When  notifying  Williams of  her  termination,  BHI  told  her it  had  a “zero 
tolerance” policy for positive drug tests, and, in its termination paperwork, BHI indicated 
that Williams’s was terminated for “fail[ing] a random drug test by the client.”  [Id. ¶ 6]. 
    Williams brought a state law claim against BHI for violating section 181.953 of 
DATWA for not giving her written notice of her right to explain the positive test, as well 

as the ability to identify non-illicit substances that may have impacted the test results as 
required under subdivision 6(b); and terminating her based on her initial positive drug 
test  in  violation  of  subdivision  10(a),  without  providing  her  with  an  opportunity  to 
participate in drug counseling or rehabilitation in violation of subdivision 10(b).  
Minn. Stat. § 181.953
, subds. 6(b), 10(a) & 10(b).  Following extensive litigation and discovery, 

Ms. Williams moved for partial summary judgment on BHI’s liability.  [Pl.’s Mot. for 
Partial Summ. J., ECF No. 102].  BHI also moved for summary judgment, arguing that 
Ms. William’s DATWA claim against her former employer was preempted by federal 

                               2                                         
law, specifically, the Atomic Energy Act.  [Def.’s Mot. for Summ. J., ECF No. 108].  The 
Court  granted  partial  summary  judgment  to  Ms. Williams,  finding  BHI  liable  for 

violating the three previously referenced subdivisions of § 181.953.  [Summ. J. Order].  
As  for  BHI,  the  Court  denied  its  motion  for  summary  judgment,  ruling  that  Ms. 
Williams’s DATWA claims against BHI were not preempted by federal law.  BHI now 
moves the Court to certify three questions for interlocutory appeal to the Eighth Circuit. 
                          DISCUSSION                                     

 I.   Standard of Review                                                 
    Interlocutory appeals in the federal system are generally disfavored.  See Firestone 
Tire & Rubber Co. v. Risjord, 
449 U.S. 368, 374
 (1981) (Ordinarily, unless the appeal 
falls within a “narrow exception,” a party must await a final judgment on the merits to 
file  an  appeal).    Frequent  use  of  §  1292(b)  requests  would  be  incompatible  with 
Congress’ intention to keep the federal courts’ final judgment rule in place and save 

interlocutory review for exceptional circumstances.  See Caterpillar v. Lewis, 
519 U.S. 61, 74
 (1996) (internal quotations omitted).  “It has long been the policy of courts to 
discourage piece-meal appeals because most often such appeals often result in additional 
burdens on both the court and the litigants.”  Union Cnty., Iowa v. Piper Jaffray & Co., 
525 F.3d 643, 646
 (8th Cir. 2008) (cleaned up).  Someone seeking interlocutory-appeal 

certification “bears the heavy burden of demonstrating that the case is an exceptional one 
in which immediate appeal is warranted.”  White v. Nix, 
43 F.3d 374, 376
 (8th Cir. 1994).  
To certify a ruling for mid-litigation appeal, a “district court must be of the opinion that 

                               3                                         
(1) the order involves a controlling question of law; (2) there is substantial ground for 
difference  of  opinion;  and  (3) certification  will  materially  advance  the  ultimate 

termination of the litigation.”  White, 
43 F.3d at 377
 (quotation omitted).  If any of these 
factors are unmet, interlocutory appeal is inappropriate.  Although the Court finds BHI is 
lacking as to all three factors, it fails the most clearly on questions two and three. 
 II.  Analysis                                                           
    A. Controlling Question of Law                                       
    The  first  element  in  assessing  whether  a  question  should  be  certified  for 

interlocutory appeal under § 1292(b) is that it involves a controlling question of law.  
28 U.S.C. § 1292
(b).  “A question of law is controlling if reversal of the district court’s order 
would terminate the action, or even if its resolution is quite likely to affect the further 
course  of  litigation.”    Varela  v.  State  Farm  Mut.  Auto.  Ins.  Co.,  Civil  No.  22-970 
(JRT/DTS), 
2023 WL 5021182
, at *3 (D. Minn. Aug. 7, 2023) (quotation omitted).   

    An issue is a question of law for purposes of § 1292(b) if it is not a matter for the 
trial court’s discretion.  White, 
43 F.3d at 377
.  That is, it cannot be a mixed question of 
law and fact.  See Fenton v. Farmers Ins. Exch., Civil No. 07-4864 (JRT/FLN), 
2010 WL 1006523
, at *2 (D. Minn. Mar. 16, 2010) (“In order for the Court to certify an order for 
an interlocutory appeal, there must be a controlling question of law, not merely a question 

of fact.”).  This means that “only pure questions of law may be certified for interlocutory 
appeal.”    Minnesota  ex  rel.  N.  Pac.  Ctr.,  Inc.  v.  BNSF  Ry.  Co.,  Civil  No.  08-6385 
(PAM/LIB), 
2010 WL 11537448
, at *2 (D. Minn. Sept. 30, 2010) (internal quotation 

                               4                                         
marks  omitted).    “Mixed  questions  of  law  and  fact  are  inappropriate  for  such  a 
proceeding.”  
Id.
                                                         

    On  its  face,  whether  federal  regulation  preempts  Williams’s  DATWA  claim 
appears to be a purely legal question.  However, in this case, the Court engaged in 
extensive consideration of the relevant facts, rendering the inquiry not one of “pure law.”  
See Varela, 
2023 WL 5021182
, at *3 (“While it is true that the resolution of this issue 
depends in part on the Court’s interpretation of the . . . policy, which is a matter of law, 
whether [Plaintiff] adequately pled a . . . claim requires application of the legal question 

to the facts of this specific case, which is not a matter of ‘pure law.’”).  In several 
respects, the Court analyzed the summary judgment factual record to reach its preemption 
decisions.  Most critically, the Court addressed the relationship between Xcel Energy (a 
nuclear licensee) and BHI (a contractor) to reach its conclusion that BHI was not directly 
covered by the NRC’s fitness-for-duty regulations.  [ECF No. 134 at 19–23].  The Court 

also carefully examined the record regarding both Xcel’s own procedures for drug tests in 
contrast to BHI’s, and what happened in this case.  [Id. at 23–26].  As such, BHI has 
failed  to  establish  that  the  questions  at  issue  are  purely  legal  as  contemplated  by  
§ 1292(b).                                                                
    B. Substantial Grounds for Difference of Opinion                     

    More importantly, the Court finds that BHI fails to make a sufficient showing as to 
the  second  factor  of  the  interlocutory  appeal  test.    There  is  substantial  ground  for 
difference of opinion when the party asking for interlocutory appeal has identified “a 

                               5                                         
sufficient  number  of  conflicting  and contradictory  opinions  [that]  provide  substantial 
ground  for  disagreement.”    White,  
43 F.3d at 378
  (internal  quotations  omitted).  

“However, substantial ground for difference of opinion does not exist merely because 
there is a dearth of cases.”  
Id.
 (citing Fed. Deposit Ins. Corp. v. First Nat’l Bank of 
Waukesha, Wis., 
604 F. Supp. 616, 620
 (E.D. Wis. 1985)).                  
    Here, the Court disagrees that there exists a substantial ground for difference of 
opinion with respect to the preemption questions raised by BHI in its motion.  Although 
the Court candidly observed places at which there was less guiding authority than usual 

in its opinion, its analysis was firmly grounded in an extensive examination of case law.  
Indeed,  BHI  points  to  no  aspects  of  the  Court’s  decision  that  are  contradicted  by 
authority,  binding  or  otherwise,  and  cites  no  authority  that  the  Court  disregarded  or 
misunderstood.  The simple reality that this case is complex or that some issues required 
close consideration simply does not satisfy the showing required for an interlocutory 

appeal.                                                                   
    C. Materially Advance the Termination of the Litigation              
    The  final  element  in  assessing  whether  a  question  should  be  certified  for 
interlocutory appeal under requires the party seeking certification of the appeal to show 
that an immediate appeal may materially advance the ultimate termination of litigation.  

28 U.S.C. § 1292
(b).  The Court may find that the third element for interlocutory appeal 
is met “if there would be a great amount of time and expense required to proceed with 
litigation  in  comparison  with  the  time  and  expense  of  staying  the  proceedings  and 

                               6                                         
pursuing an immediate appeal.”  Fenton, 
2010 WL 1006523
, at *2.  It is as to this factor 
that BHI makes the weakest showing of all.                                

    Here, the Court finds that BHI has not met their burden of demonstrating that an 
immediate appeal will save any real time or expense.  At this stage, only a damages trial 
remains.  A motion to dismiss, full discovery, and summary judgment have already been 
completed.  Very little is left to be done, so there is minimal efficiency in having an 
appeal now as opposed to following the damages finding and entry of judgment.  Given 
the procedural stage of this litigation, this case is not one of the unique situations where 

the rarely used tool of interlocutory appeal should be utilized.          
                    CONCLUSION and ORDER                                 
    Because  BHI  failed  to  satisfy  the  three  elements  required  under  
28 U.S.C. § 1292
(b) to certify its three questions for interlocutory appeal of the Court’s August 24, 
2023, Order, the Court denies BHI’s Motion for Certification.  Based on the foregoing 

analysis and all the files, records and proceedings herein, IT IS HEREBY ORDERED 
that Defendant BHI Energy I Power Services LLC’s Motion to Certify Interlocutory 
Appeal, [ECF No. 145], is DENIED.                                         


Date: March 7, 2024              s/Katherine Menendez                     
                                Katherine Menendez                       
                                United States District Court             


                               7                                         

Reference

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