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Blount V Whole Foods Market Downtown Nashville

                  UNITED STATES DISTRICT COURT                           
              FOR THE MIDDLE DISTRICT OF TENNESSEE                       
                       NASHVILLE DIVISION                                


ALIVIA BLOUNT,                                                           

     Plaintiff,                 Case No. 3:23-cv-00343                   

v.                              Judge Waverly D. Crenshaw, Jr.           
                                Magistrate Judge Alistair E. Newbern     
WHOLE FOODS MARKET DOWNTOWN                                              
NASHVILLE,                                                               

     Defendant.                                                          


                     MEMORANDUM ORDER                                    
    There are sixteen motions pending in this action (Doc. Nos. 63, 71, 73, 74, 79, 80, 84, 89, 
93, 95–97, 101, 113–15), many of which stem from the parties’ apparent confusion about orders 
the Court issued in screening pro se Plaintiff Alivia Blount’s amended complaint (Doc. Nos. 7, 9, 
11). Specifically, the parties have spilled a great deal of ink debating whether the claim Blount 
asserts against Defendant Whole Foods Market Downtown Nashville arises under 42 U.S.C. 
§ 2000a or 42 U.S.C. § 1981. Because the Court found in its final screening order “that Blount has 
stated a non-frivolous  Section 1981 claim for discrimination by a retail establishment” and 
dismissed “[a]ll other claims” (Doc. No. 11, PageID# 49), the pending motions raise issues that 
are not in dispute and do little to move this action forward.             
    Accordingly, and for the reasons that follow, the Court will direct the Clerk of Court to 
administratively terminate the parties’ summary judgment motions and other motions rooted in a 
dispute over the operative cause of action. The Court will separately address Blount’s motion for 
sanctions (Doc. No. 93), motion to appoint counsel (Doc. No. 113), request for electronic service 
of documents (Doc. No. 115), and request for a PACER fee exemption (Doc. No. 114). 
I.    Relevant Background                                                  
     Blount initiated this action on April 13, 2023, by filing a complaint against Whole Foods 
for racial discrimination. (Doc. No. 1.) The Court granted Blount’s application for leave to appear 
in forma pauperis (Doc. Nos. 5, 7), consolidated this action with another action Blount filed 
against Whole Foods (Doc. No. 9), and ordered Blount to file “one Amended Complaint that 

identifies all of [her] legal claims and includes factual allegations sufficient to demonstrate a 
plausible right to relief” within thirty days of the Court’s order (id. at PageID# 36). Three days 
later, Blount filed a motion requesting access to the Court’s CM/ECF electronic filing system 
(Doc. No. 10) and attached an “updated complaint” against Whole Foods (id. at PageID# 41). The 
Court treated Blount’s updated complaint (Doc. No. 10) as the ordered amended pleading and, on 
November 2, 2023, screened Blount’s amended complaint under 28 U.S.C. § 1915(e)(2)(B). (Doc. 
No. 11.)  The  Court  found  “that  Blount  has  stated  a  non-frivolous  Section 1981  claim  for 
discrimination by a retail establishment.” (Id. at PageID# 49.)           
     The Court then referred the action to the Magistrate Judge to dispose or recommend 
disposition of any pretrial motions under 28 U.S.C. § 636(b)(1)(A) and (B). (Doc. No. 11.) On 

November 3, 2023, the Magistrate Judge granted Blount’s motion for CM/ECF access (Doc. 
No. 10) and directed the Clerk of Court to file Blount’s screened amended complaint as a separate 
docket entry. (Doc. No. 12.) The Clerk of Court did so on the same day. (Doc. No. 13.) 
     Whole Foods filed an answer to Blount’s amended complaint. (Doc. No. 23.) The Court 
entered a scheduling order setting September 30, 2024, as the deadline to file motions to amend 
the pleadings; January 30, 2025, as the deadline to complete discovery; and March 31, 2025, as 
the deadline to file dispositive motions. (Doc. No. 49.) This case is set for a jury trial on December 
2, 2025. (Doc. No. 50.)                                                   
II.    Analysis                                                             
      In its final screening order, the Court found that “Blount claims that Whole Foods engaged 
 in ‘racial profiling’ in connection with false allegations of retail theft.” (Doc. No. 11, PageID# 48.) 
 The  Court  “liberally  construe[d]  this  as  a  claim  under  42  U.S.C.  § 1981,  which  prohibits 
 discrimination in the making and enforcement of contracts and has been applied in the context of 

 alleged discrimination by a retail establishment.” (Id. (collecting authority).) The Court then found 
 that  Blount  had  “plausibly  alleged”  the  elements  of  a  § 1981  claim  against  Whole  Foods, 
 including:                                                                
      that she is a member of a protected class; she sought to purchase goods ordinarily 
      provided by Whole Foods; and she was deprived of her right to purchase those 
      goods in a hostile manner that a reasonable person could find discriminatory. 
 (Id. at PageID# 49.)                                                      
      The Court thus “conclude[d] that Blount has stated a non-frivolous Section 1981 claim for 
 discrimination by a retail establishment” and dismissed “[a]ll other claims . . . .” (Id.) 
      No party challenged the Court’s construction of Blount’s claim. Accordingly, the screening 
 order’s direction that all parties construe Blount’s amended complaint (Doc. No. 13) as asserting 
 a claim under § 1981 is the law of the case. See Arizona v. California, 460 U.S. 605, 618 (1983) 
 (holding that, under law-of-the-case doctrine, “when a court decides upon a rule of law, that 
 decision should continue to govern the same issues in subsequent stages in the same case”); 
 Christianson v. Colt Indus. Operating Corp., 486 U.S. 800, 816 (1988) (noting that law-of-the-
 case doctrine “promotes the finality and efficiency of the judicial process by ‘protecting against 
 the agitation of settled issues’” (citation omitted)).                    
    A.   The  Parties’  Summary  Judgment  Motions,  Related  Filings,  and  Other 
         Motions That Do Not Reflect the Law of the Case                 
    On February 21, 2025, Blount filed a motion for summary judgment (Doc. No. 63) to which 
Whole Foods filed a response (Doc. No. 68). Blount argues in her motion that Whole Foods’ 
actions constitute “racial discrimination and profiling under Title II of the Civil Rights Act of 
1964, places of public accommodation [42 U.S.C. § 2000a]” and does not cite § 1981. (Doc. 
No. 63, PageID# 225.) Whole Foods responds in opposition that, “although this Court ordered 
Plaintiff to amend her Original Complaint . . . to bring her claims under 42 U.S.C. § 1981, Plaintiff 
did not do so.” (Doc. No. 68, PageID# 239.) Both parties’ filings misrepresent the Court’s prior 
orders. First, Blount cites “Title II of the Civil Rights Act of 1964” as the statutory basis for her 

claim instead of § 1981, the statute under which the Court found she had plausibly alleged a cause 
of action. Blount thus misstates the Court’s construction of her claim. Second, Whole Foods argues 
that the Court ordered Blount to amend her complaint to bring her claims under § 1981 and that 
Blount did not do so. But the Court’s screening order addressed Blount’s amended complaint and 
construed it as asserting a claim under § 1981. The Court did not order Blount to file a second 
amended pleading.1 (Doc. No. 11.)                                         
    Whole Foods then filed its own motion for summary judgment. (Doc. No. 74.) Whole 
Foods’ only argument in support of summary judgment is that Blount cannot show that she is 
entitled to monetary relief because she “brings her claims solely under . . . § 2000a” which “only 



1    Whole Foods’ confusion in this regard may arise from the fact that Blount filed the 
amended complaint as an attachment to her motion for PACER access (Doc. No. 10). After the 
Court entered its screening order (Doc. No. 11), it ordered the Clerk’s Office to docket the 
amended complaint as a separate docket entry (Doc. No. 12). What the Clerk’s Office docketed 
(Doc. No. 13) is the same pleading (Doc. No. 10) addressed by the Court’s screening order (Doc. 
No. 11) construing Blount’s claim as arising under § 1981.                
authorizes injunctive relief as a remedy.” (Doc. No. 74-1, PageID# 297.) This argument, of course, 
does not reflect the law of the case.                                     
    In response to Whole Foods’ assertion that she has only brought a § 2000a claim, Blount 
filed several motions and pleadings asking the Court for leave to amend her summary judgment 

motion and complaint to clarify that she is seeking relief under § 1981. (Doc. Nos. 79, 83–85, 101.) 
Whole Foods has moved to strike several of these motions and pleadings (Doc. Nos. 89, 95–97), 
and Whole Foods opposes Blount’s efforts to “amend” her cause of action from a § 2000a claim 
to a § 1981 claim at this stage of the proceedings (Doc. Nos. 90, 92).    
    As explained above, however, Blount’s operative cause of action has been a § 1981 claim 
since the Court entered its screening order on November 2, 2023 (Doc. No. 11).2 Whole Foods’ 
assertion that Blount “made the conscious choice to ignore the Court’s construction of her claims 
and proceed solely under 42 U.S.C. § 2000a” by filing a “Second Amended Complaint [Doc. 13]” 
after the Court screened “her First Amended Complaint [Doc. 10]” (Doc. No. 86, PageID# 393 
(brackets in original)) is incorrect. As the Court recognized in its November 6, 2024 order, “[t]he 

amended complaint (Doc. No. 13), as screened by the Court (Doc. No. 11), is [ ] the operative 
pleading in this action.” (Doc. No. 56, PageID# 182.)                     
    The docket is cluttered with motions and briefing dedicated to the parties’ back-and-forth 
over what claim Blount asserts, none of which is relevant to resolving Blount’s § 1981 claim and 
all of which are rendered moot by the Court’s final screening order. To move this case forward, 

2    The Court made its own misstatement in this regard. The Court’s February 23, 2024 order 
addressing Whole Foods’ motion to strike Blount’s reply to Whole Foods’ answer incorrectly 
stated that “Blount’s amended complaint in this action asserts a claim . . . under 42 U.S.C. § 2000a 
for discrimination in a place of public accommodation.” (Doc. No. 28, PageID# 110.) However, 
in a subsequent order, the Court explained the procedural history of Blount’s § 1981 claim in detail 
and confirmed that “[t]he amended complaint (Doc. No. 13), as screened by the Court (Doc. 
No. 11), is [ ] the operative pleading in this action.” (Doc. No. 56, PageID# 182.) 
the Court will administratively terminate the parties’ summary judgment motions, related motions, 
and other motions rooted in the mistaken assertion that Blount is pursuing a claim under § 2000a 
(Doc. Nos. 63, 71, 73, 74, 79, 80, 84, 89, 95–97, 101) and will allow the parties an opportunity to 
refile dispositive motions addressing the operative § 1981 claim.         

    B.   Blount’s Remaining Motions                                      
    Blount’s motion for sanctions (Doc. No. 93), motion to appoint counsel (Doc. No. 113), 
request for electronic service of documents (Doc. No. 115), and request to be exempt from PACER 
fees (Doc. No. 114) are ripe for resolution.                              
         1.   Motion for Sanctions                                       
    Blount asks the Court to sanction Whole  Foods for “litigation abuse  and discovery 
violations[.]” (Doc. No. 93, PageID# 481.) Specifically, Blount argues that the Court should 
impose sanctions on Whole Foods for its “insistence that [she] initiate an entirely new legal action 
to assert claims under 42 U.S.C. § 1981” in opposing her motions to amend and for summary 
judgment and for “fail[ing] to respond to [her] interrogatories in a complete and good faith 
manner.” (Id. at PageID# 481–82.)                                         

    The Court has already  addressed  Whole  Foods’ incorrect understanding of Blount’s 
operative § 1981 claim and ordered the termination of pending motions reflecting that unsupported 
position. Sanctions are not warranted on this ground.                     
    Blount’s motion also fails in its request for discovery sanctions. Blount previously moved 
for an order compelling Whole Foods to respond to her discovery requests and for discovery 
sanctions. (Doc. Nos. 57, 58.) In its order denying Blount’s motion without prejudice, the Court 
instructed Blount that, before she files a discovery-related motion, she must try to resolve the 
dispute  independently  with  Whole  Foods’  counsel.  (Doc.  No. 67.)  If  that  effort  proves 
unsuccessful, the Court instructed, Blount must request a discovery dispute resolution conference 
with the Court. (Id.) Blount’s motion does not reflect that she conferred with Whole Foods’ 
counsel, and she has not requested a discovery dispute resolution conference with the Court. 
Further, Blount filed this motion more than two months after the scheduling order deadline for 
filing discovery motions. (Doc. No. 49.) For these reasons, the motion for sanctions will be denied. 

    The Court notes, however, that Blount cites as a ground for sanctions that Whole Foods 
“[r]efused to work in good faith to resolve discovery disputes or streamline legal issues.” (Doc. 
No. 93, PageID# 485.) Blount also states that Whole Foods “[s]imultaneously refused discovery 
and  filed  dispositive  motions  claiming  the  facts  were  insufficient  or  unsupported.”  (Id.  at 
PageID# 484.) As this action moves forward, Blount may choose to follow the Court’s discovery 
dispute resolution procedures or seek remedies provided in the Federal Rules of Civil Procedure 
to bring these or other issues to the Court’s attention. The denial of Blount’s motion for sanctions 
is without prejudice to doing so.                                         
         2.   Motion to Appoint Counsel                                  
    Blount asks the Court to appoint counsel to represent her in this action pursuant to 28 
U.S.C. § 1915(e)(1). (Doc. No. 113.) Blount states that she “is unable to afford retained counsel” 

and argues that appointment of counsel is warranted because “[t]his case involves complex legal 
issues,” she “has limited legal training and, despite best efforts, [she] is not able to adequately 
represent her interests at trial.” (Id. at PageID# 551.)                  
    In civil actions, unlike criminal proceedings, there is no constitutional right to counsel. 
Lavado v. Keohane, 992 F.2d 601, 605–06 (6th Cir. 1993) (“‘Appointment of counsel in a civil 
case is not a constitutional right.’” (quoting Wahl v. McIver, 773 F.2d 1169, 1174 (11th Cir. 
1985))); Hollis v. Perry, No. 3:17-cv-00626, 2018 WL 3572391, at *2 (M.D. Tenn. July 24, 2018) 
(citing Willett v. Wells, 469 F. Supp. 748, 751 (E.D. Tenn. 1977), for the proposition that “there is 
no constitutional right to an appointed counsel in a civil action”). District courts have discretion to 
appoint counsel for indigent civil litigants under 28 U.S.C. § 1915(e)(1), but there must be 
exceptional circumstances justifying such an appointment. See Lavado, 992 F.2d at 606 (quoting 
Wahl, 773 F.2d at 1174); Childs v. Pellegrin, 822 F.2d 1382, 1384 (6th Cir. 1987) (interpreting 
then § 1915(d)). To determine “whether exceptional circumstances exist, a district court considers 

the type of case, the ability of the pro se litigant to represent himself or herself, and the nature of 
the factual and legal issues involved.” Hollis, 2018 WL 3572391, at *2.   
    At this stage of the proceedings, the Court finds no exceptional circumstances to warrant 
appointment of counsel. Blount’s lack of legal training and inability to afford counsel are common 
to many pro se civil rights plaintiffs, most of whom will not be appointed counsel. The factual and 
legal issues in this case are not unusually complex. And Blount has shown in her pleadings and 
motions filed to date that she can communicate with the Court effectively. (Doc. Nos. 1, 2, 5, 6, 8, 
10, 15–17, 19, 20, 24, 29–31, 39, 40, 43–47, 52, 53, 57–59, 63–65, 70–73, 75, 77–80, 82–85, 91, 
93, 94, 98–101, 107–09, 111, 113–16.) If circumstances of this case change—for example, if 
Blount’s claim proceeds past summary judgment—Blount may raise the issue of appointed counsel 

again.                                                                    
         3.   Request for Electronic Service of Documents                
    Blount filed a request for “permission to receive all filings and orders in this matter via 
electronic service.” (Doc. No. 115, PageID# 554.) Two days later, Blount filed a completed and 
signed copy of the Court’s consent to electronic service form for pro se litigants. (Doc. No. 116.) 
    Because Blount signed and filed the consent to electronic service form, she “will receive a 
notice of electronic filing by e-mail when the court enters an order, or when a party files a 
document through CM/ECF.” (Id.) Blount “will be permitted one ‘free look’ at the filed document 
by clicking on the hyperlinked document number” in the email and can “download the document 
to [her] own files to access it again without charge.” (Id.)              
    Blount’s request for electronic service of documents (Doc. No. 115) is therefore moot. 
         4.   Request for PACER Fee Exemption                            
    Blount also “requests an exemption from PACER access fees under the Electronic Public 
Access Fee schedule.” (Doc. No. 114.) Blount states that she “has been granted in forma pauperis 
status in this matter and lacks the financial resources to pay for PACER access.” (Id.) 

    “PACER, an acronym for Public Access to Electronic Records, is the service that provides 
electronic access via the Internet to case and docket information from the federal courts.” Martin 
v. Cole, Case No. 24-cv-11256, 2024 WL 3448456, at *2 n.1 (E.D. Mich. July 16, 2024). “The 
Judicial Conference of the United States has established fees for access to information in PACER.” 
Stinson v. Fowlkes, No. 2:22-cv-02694, 2023 WL 3938880, at *8 (W.D. Tenn. June 9, 2023); see 
also 28 U.S.C. § 1914 note (Judicial Conference Schedule of Fees, Electronic Public Access Fee 
Schedule); U.S. Courts, Electronic Public Access Fee Schedule, https://www.uscourts.gov/court-
programs/fees/electronic-public-access-fee-schedule (last visited July 21, 2025). PACER users 
pay ten cents per page to download documents, with a maximum charge of three dollars per 
document. 28 U.S.C. § 1914 note (Judicial Conference Schedule of Fees, Electronic Public Access 

Fee Schedule). There are no fees for accessing judicial opinions or for viewing case information 
or documents at courthouse public access terminals. Id. Parties in a case, including pro se litigants 
and attorneys of record, receive one free electronic copy of most electronically filed documents. 
Id.                                                                       
    The Judicial Conference has authorized courts to “exempt certain persons or classes of 
persons from payment of the use access fee[,]” including “indigents,” if those “seeking an 
exemption [ ] demonstrate[ ] that an exemption is necessary in order to avoid unreasonable burdens 
and to promote public access to information[.]” Id. at ¶ 9. “To be eligible for an exemption from 
PACER user fees, the requesting party must show that an exemption is necessary to: (1) avoid 
 unreasonable burden; and (2) promote public access to information.” Martin, 2024 WL 3448456, 
 at  *2;  see  also  PACER,  Options  to  Access  Records  if  you  Cannot  Afford  PACER  Fees, 
 https://pacer.uscourts.gov/my-account-billing/billing/options-access-records-if-you-cannot-
 afford-pacer-fees (last visited July 21, 2025) (“A court will grant an exemption upon finding that 

 the requesting party has demonstrated that an exemption is necessary to avoid unreasonable 
 burdens and to promote public access to information.”).                   
      Blount has not shown that a PACER fee exemption is necessary to avoid unreasonable 
 burdens here. The Court granted Blount in forma pauperis status because it found that Blount 
 “adequately demonstrate[d] that she cannot pay the full civil filing fee in advance without ‘undue 
 hardship.’” (Doc. No. 7, PageID# 26 (quoting Foster v. Cuyahoga Dep’t of Health & Hum. Servs., 
 21 F. App’x 239, 240 (6th Cir. 2001); and citing 28 U.S.C. § 1915(a)).) But Blount’s in forma 
 pauperis status does not automatically entitle her to exemption from PACER fees. See, e.g., Malouf 
 v. Detroit Med. Ctr., No. 10-cv-14763, 2011 WL 1465787, at *1 (E.D. Mich. Apr. 18, 2011) 
 (“While Plaintiff may be unable to afford the filing fees associated with this lawsuit, the Court 

 finds that he is financially capable of affording the minimal costs of the PACER system.”). Further, 
 because Blount has consented to electronic service of documents in this case, she will receive a 
 free electronic copy of most documents filed in this case. The Court finds it likely that Blount has 
 effectively received the relief she sought through this motion.           
      Blount’s request for a PACER fee exemption (Doc. No. 114) will therefore be denied 
 without prejudice.                                                        
III.   Conclusion                                                           
      For these reasons, and in the interests of moving this case toward just and efficient 
 resolution, the Clerk of Court is DIRECTED TO ADMINISTRATIVELY TERMINATE the 
 following motions:                                                        
      •  Blount’s motion for summary judgment (Doc. No. 63);             
      •  Blount’s proposed order granting her motion for summary judgment (Doc. No. 71); 
      •  Blount’s request for a timely ruling on her motion for summary judgment (Doc. 

         No. 73);                                                        
      •  Whole Foods’ motion for summary judgment (Doc. No. 74);         
      •  Blount’s supplemental motion for summary judgment (Doc. No. 79); 
      •  Blount’s motion to request a summary judgment ruling and to preclude further 
         unauthorized filings by Whole Foods (Doc. No. 80);              
      •  Blount’s motion for leave to file an amended complaint (Doc. No. 84); 
      •  Whole  Foods’  motion  to  strike  Blount’s  supplemental  motion  for  summary 
         judgment and summary judgment declaration (Doc. No. 89);        

      •  Whole Foods’ twice-filed motion to strike Blount’s supplement to her motion for 
         summary judgment (Doc. Nos. 95, 96);                            
      •  Whole  Foods’  motion  to  strike  Blount’s  proposed  amended  complaint  (Doc. 
         No. 97); and                                                    
      •  Blount’s  motion  for  leave  to  supplement  or  amend  her  motion  for  summary 
         judgment (Doc. No. 101).                                        
    Blount’s amended complaint (Doc. No. 13) as screened by the Court (Doc. No. 11) remains 
the operative pleading in this action. Blount and Whole Foods may refile dispositive motions 
addressing Blount’s § 1981 claim by August 6, 2025. Responses in opposition must be filed by 

August 27, 2025, and optional replies may be filed by September 3, 2025.  
    Blount’s motion for sanctions (Doc. No. 93) is DENIED.               
    Blount’s motion to appoint counsel (Doc. No. 113) is DENIED WITHOUT PREJUDICE. 
     Blount’s  request  for  an  exemption  from  PACER  fees  (Doc.  No. 114)  is  DENIED 
WITHOUT PREJUDICE. 
     Blount’s request for electronic service of documents (Doc. No. 115) is FOUND MOOT. 
     By separate order, the Court will appoint a pro bono mediator and require the parties to 
mediate this action by no later than September 30, 2025. 
     It is so ORDERED. 

                                         Abistow nolborr 
                                         ALIST     E. NEWBERN 
                                         United States Magistrate Judge 

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