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Home Court filings BST Holdings, L.L.C. v. Occupational Safety and Health Administration Petition for Review — BST Holdings v. OSHA

Court filing

Petition for Review — BST Holdings v. OSHA

Filed November 5, 2021 in BST Holdings, L.L.C. v. Occupational Safety and Health Administration; one of 2 filings from this case.

Record facts

CourtU.S. Court of Appeals for the Fifth Circuit
Filed2021-11-05

U.S. Court of Appeals for the Fifth Circuit · No. 21-60845 · Doc. 1-1 · 2021-11-05 · Docket on CourtListener

Full text

1 
No. 21-_____________ 
__________________________________________________________________ 
 
UNITED STATES COURT OF APPEALS 
FOR THE FIFTH CIRCUIT 
__________________________________________________________________ 
 
BST Holdings, LLC; RV Trosclair L.L.C.; Trosclair Airline LLC; 
Trosclair Almonaster LLC; Trosclair and Sons LLC; Trosclair & 
Trosclair, Inc.; Trosclair Carrollton LLC; Trosclair Claiborne LLC; 
Trosclair Donaldsonville, LLC; Trosclair Houma LLC; Trosclair Judge 
Perez LLC; Trosclair Lake Forest LLC; Trosclair Morrison LLC; 
Trosclair Paris LLC; Trosclair Terry LLC; Trosclair Williams LLC; 
Ryan Dailey; Jasand Gamble; Christopher L. Jones; David John 
Loschen; Samuel Albert Reyna; and Kip Stovall, 
 
Petitioners,     
 
v. 
 
Occupational Safety and Health Administration,  
United States Department of Labor, 
 
Respondent. 
__________________________________________________________________ 
 
PETITION FOR REVIEW 
__________________________________________________________________ 
 
Daniel R. Suhr 
 
Sarah Harbison 
Jeffrey D. Jennings  
 
Pelican Institute for Public Policy 
Liberty Justice Center 
 
400 Poydras St., Suite 900 
141 W. Jackson Blvd., Ste. 1065 
New Orleans, LA 70130 
Chicago, IL 60604 
 
Telephone: 504-952-8016 
Telephone: 312-637-2280 
 
sarah@pelicaninstitute.org 
dsuhr@libertyjusticecenter.org 
jjennings@libertyjusticecenter.org Attorneys for Petitioners 
 
Case: 21-60845      Document: 1-1     Page: 1     Date Filed: 11/05/2021

 
2 
 
CERTIFICATE OF INTERESTED PERSONS 
1. 
Pursuant to Fifth Circuit Rule 28.2.1, Petitioners file this 
Certificate of Interested Persons. The case number has yet to be assigned 
in this case, and the complete case caption of parties is on the preceding 
cover page. 
2. 
The undersigned counsel of record certifies that the following 
listed persons and non-governmental entities have an interest in the 
outcome of this case. These representations are made in order that the 
judges of this Court may evaluate possible disqualification or recusal.  
a. 
BST Holdings, LLC 
b. 
RV Trosclair L.L.C. 
c. 
Trosclair Airline LLC 
d. 
Trosclair Almonaster LLC 
e. 
Trosclair and Sons LLC 
f. 
Trosclair & Trosclair, Inc. 
g. 
Trosclair Carrollton LLC 
h. 
Trosclair Claiborne LLC 
i. 
Trosclair Donaldsonville, LLC 
j. 
Trosclair Houma LLC 
Case: 21-60845      Document: 1-1     Page: 2     Date Filed: 11/05/2021

 
3 
k. 
Trosclair Judge Perez LLC 
l. 
Trosclair Lake Forest LLC 
m. 
Trosclair Morrison LLC 
n. 
Trosclair Paris LLC 
o. 
Trosclair Terry LLC 
p. 
Trosclair Williams LLC 
q. 
Ryan Dailey 
r. 
Jasand Gamble 
s. 
Christopher L. Jones 
t. 
David John Loschen 
u. 
Samuel Albert Reyna 
v. 
Kip Stovall 
3. 
Opposing counsel in this case will be the United States 
Department of Justice. 
/s/ Jeffrey D. Jennings 
 
 
Attorney of record for Petitioners 
 
 
Case: 21-60845      Document: 1-1     Page: 3     Date Filed: 11/05/2021

 
4 
PETITION FOR REVIEW 
Pursuant to § 6(f) of the Occupational Safety and Health Act, 28 
U.S.C. § 655(f), and Federal Rule of Appellate Procedure 15, the 
Petitioners, BST Holdings, LLC; RV Trosclair L.L.C.; Trosclair Airline 
LLC; Trosclair Almonaster LLC; Trosclair and Sons LLC; Trosclair & 
Trosclair, Inc.; Trosclair Carrollton LLC; Trosclair Claiborne LLC; 
Trosclair Donaldsonville, LLC; Trosclair Houma LLC; Trosclair Judge 
Perez LLC; Trosclair Lake Forest LLC; Trosclair Morrison LLC; Trosclair 
Paris LLC; Trosclair Terry LLC; Trosclair Williams LLC; Ryan Dailey; 
Jasand Gamble; Christopher L. Jones; David John Loschen; Samuel 
Albert Reyna; and Kip Stovall (“Petitioners”), petition the Court for 
review of the Emergency Temporary Standard addressing occupational 
exposure to COVID-19, issued by the Respondent, Occupational Safety 
and Health Administration, United States Department of Labor (“OSHA” 
or “Respondent”), and published in the Federal Register on November 5, 
2021, at Volume 86, pages 61402 through 61555 (the “ETS”). A copy of 
the ETS is attached to this Petition as Exhibit A. 
The ETS requires all employers with more than 100 employees to 
mandate that their workers be fully vaccinated against COVID-19—or to 
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subject unvaccinated workers to weekly COVID-19 testing and masking 
at work. Petitioners petition for review of this ETS mandate on the 
grounds that 1) it exceeds OSHA’s authority under its enabling statute, 
2) it exceeds Congress’s authority under the Interstate Commerce 
Clause, and 3) it exceeds Congress’s authority under the nondelegation 
doctrine. 
The sixteen corporate entity petitioners are a management 
company and fifteen locally owned supermarkets that conduct business 
under the names Ralph’s Market, Butcher Boy, and Save A Lot. The 
earliest market has been in continuous operation in Louisiana since 
1984. They share common ownership and common management, as 
Brandon Trosclair is the single member-manager of the limited liability 
companies and the president of the incorporated entity. They are all 
incorporated in Louisiana and maintain their principal place of business 
in Louisiana. Combined, they employ almost 500 workers and are 
currently subject to OSHA regulations. They will be adversely affected 
by the ETS because they already face worker shortages, and the ETS 
would make it even harder to hire and keep employees. The ETS would 
diminish their ability to provide grocery options to the citizens of 
Case: 21-60845      Document: 1-1     Page: 5     Date Filed: 11/05/2021

 
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Louisiana. 
The six individually named petitioners are residents of Texas and 
employees 
of 
CaptiveAire 
Systems, 
Inc., 
a 
corporation 
with 
approximately 1,500 employees. They will be adversely affected by the 
ETS because it will force them, against their will, to show their employer 
proof of COVID-19 vaccination or risk losing their jobs and livelihoods if 
they choose not to. Alternatively, they would be subjected to weekly 
COVID-19 testing and masking at work. This adverse effect is 
particularly troubling, unfair, and illegal as it applies to Petitioners 
Dailey, Gamble, Jones, and Reyna because they work mostly alone on 
roofs and are highly unlikely to spread COVID-19 to colleagues they may 
only see a few times a year. They only come into contact with customers 
briefly at customer workplaces. Therefore, OSHA’s claimed authority 
over their private lives and vaccine status is an egregious government 
overreach. 
For these reasons, Petitioners petition this Court to review the ETS 
immediately, and they plan to file today an Emergency Motion to Stay 
Enforcement & Expedite Review and their Opening Brief. 
 
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November 5, 2021 
Respectfully submitted, 
/s/ Jeffrey D. Jennings 
 
 
 
Daniel R. Suhr, WI Bar # 1056658 
 
Application for Admission Submitted 
Jeffrey D. Jennings, VA Bar # 87667  
Liberty Justice Center 
141 W. Jackson Blvd., Ste. 1065 
Chicago, IL 60604 
Telephone: 312-637-2280 
dsuhr@libertyjusticecenter.org 
 
jjennings@libertyjusticecenter.org 
 
 
Sarah Harbison, LA Bar # 31948 
 
Pelican Institute for Public Policy 
 
400 Poydras St., Suite 900 
 
New Orleans, LA 70130 
 
Telephone: 504-952-8016 
 
sarah@pelicaninstitute.org 
 
 
Attorneys for Petitioners 
 
 
Case: 21-60845      Document: 1-1     Page: 7     Date Filed: 11/05/2021

 
8 
CERTIFICATE OF SERVICE 
 
 
I hereby certify that on November 5, 2021, I caused a copy of this 
Petition for Review to be served on Respondent by email as directed in 
the ETS: 
Edmund C. Baird 
Associate Solicitor of Labor for Occupational 
Safety and Health 
Office of the Solicitor 
United States Department of Labor 
200 Constitution Ave., NW 
Washington, DC 20210 
zzSOLCovid19-ETS@dol.gov  
 
/s/ Jeffrey D. Jennings 
 
Case: 21-60845      Document: 1-1     Page: 8     Date Filed: 11/05/2021

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