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TAYLOR v. PHOENIXVILLE SCHOOL DIST.

September 19, 2000

KATHERINE L. TAYLOR, PLAINTIFF,
V.
PHOENIXVILLE SCHOOL DISTRICT, DEFENDANT.



The opinion of the court was delivered by: Joyner, District Judge.

MEMORANDUM

This is an employment discrimination case presently before the Court on remand from the United States Court of Appeals for the Third Circuit. Plaintiff Katherine L. Taylor ("Plaintiff" or "Taylor") brought this action against her former employer, Defendant Phoenixville School District ("Defendant" or "the School District"), on December 19, 1996. In her Complaint, Taylor claimed that the School District discriminated against her in violation of the Americans with Disabilities Act, 42 U.S.C. § 12101, et seq. ("the ADA") and the Pennsylvania Human Relations Act, 43 P.S. § 951, et seq. ("the PHRA"). The essence of Taylor's claims was that the School District failed to provide reasonable accommodations for her mental illness.

Defendant moved for summary judgment pursuant to Fed.R.Civ.P. 56 on September 17, 1997. On March 20, 1998, we granted Defendant's Motion for Summary Judgment in our opinion reported at 998 F. Supp. 561 (E.D.Pa. 1998). Plaintiff appealed. On appeal, the Third Circuit reversed our order, concluding that Taylor's unmedicated condition demonstrated that she had a disability. In addition, the court found that genuine factual issues existed as to whether the School District participated in the interactive process required by the ADA. See Taylor v. Phoenixville Sch. Dist., 174 F.3d 142 (3d Cir. Apr.5, 1999).

Shortly thereafter, Defendant petitioned for rehearing. The Third Circuit ultimately granted Defendant's petition and vacated its earlier opinion in light of the recent United States Supreme Court decisions in Sutton v. United Airlines, Inc., 527 U.S. 471, 119 S.Ct. 2139, 144 L.Ed.2d 450 (1999) and Murphy v. United Parcel Svc., 527 U.S. 516, 119 S.Ct. 2133, 144 L.Ed.2d 484 (1999). In Sutton and Murphy, the Supreme Court held that when a court evaluates whether a plaintiff has a disability under 42 U.S.C. § 12102(A), it must take into account any mitigating measures the plaintiff uses. Based on these decisions, the Third Circuit on August 18, 1999 issued a new opinion, in which it applied the updated law.

In its August 1999 opinion, the Third Circuit again reversed the grant of summary judgment, concluding that genuine issues of fact existed as to whether Taylor continued to be substantially limited in a major life activity even while taking her medication. The court also restated its previous conclusions regarding the interactive process, which were unaffected by Sutton and Murphy. The case was then remanded to this Court for further proceedings. Taylor v. Phoenixville School District, 184 F.3d 296 (3d Cir. 1999).

Upon remand, we granted the parties time to perform additional discovery. Having completed that additional discovery, Defendant now moves again for summary judgement on all counts. For the reasons that follow, we will grant Defendant's Motion in part and deny it in part.

BACKGROUND

As both this Court and the Third Circuit have previously stated the facts of this case at length, we need not duplicate those efforts here. The essential facts of the case are as follows. Plaintiff was employed by Defendant as the principal's secretary for the East Pikeland Elementary School ("East Pikeland") from September 1974 until her termination on October 28, 1994. During her tenure as secretary, Plaintiff worked for several different principals, each of whom gave Plaintiff consistently positive work reviews. In August 1993, a new principal, Christine Menzel ("Menzel"), was assigned to East Pikeland. Unfortunately, after working with Menzel for only one week, Plaintiff became ill and was forced to take a leave of absence from work.

Plaintiff's leave of absence began on August 30, 1993. The next day she was admitted to the Coastal Plains Hospital and Counseling Center in North Carolina ("Coastal Plains") where she was diagnosed with bipolar disorder. While under care at Coastal Plains, Plaintiff was treated with the prescription drugs Navane and Lithium Carbonate. She remained hospitalized until September 20, 1993, at which time she was discharged to the care of Louise Sonnenberg, M.D. ("Dr. Sonnenberg"), a psychiatrist practicing in Phoenixville, Pennsylvania. Plaintiff currently remains under the care of Dr. Sonnenberg and continues to take Lithium.

With her doctor's permission, Plaintiff returned to work in mid-October 1993. Almost immediately upon her return, Plaintiff encountered difficulties performing her job. These problems were exacerbated by a number of changes in office procedure that had been implemented by Menzel during Plaintiff's absence. As a result of the problems, Menzel became dissatisfied with Plaintiff's performance, and the working relationship between the two women became strained. Over the next year, Menzel documented Plaintiff's errors in a series of disciplinary memoranda that culminated with Plaintiff being placed on probation for unsatisfactory performance on September 8, 1994. Finally, on October 28, 1994, Plaintiff was informed that she had failed to improve her performance during the probationary period and that she was being terminated from her position.

After Plaintiff's termination, her union representatives negotiated with the School District to allow her to "retire" in substitution for her discharge, thereby allowing her to receive retirement benefits. Several months later, Plaintiff filed this action.

DISCUSSION

I. Legal Standard

Summary judgment is appropriate "if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law." Fed.R.Civ.P. 56(c). The moving party bears the initial burden of showing the basis for its motion for summary judgment. Celotex Corp. v. Catrett, 477 U.S. 317, 323, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986). Once the moving party meets this burden pursuant to Fed.R.Civ.P. 56(c), the burden shifts to the non-moving party to go beyond mere pleadings and to demonstrate, through affidavits, depositions or admissions, that a genuine issue exists for trial. Id. at 324, 106 S.Ct. 2548. In so doing, the non-moving party must raise "more than a mere scintilla of evidence in its favor" and may not merely rely on unsupported ...


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