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Snyder v. Commonwealth

October 27, 2010


The opinion of the court was delivered by: Yvette Kane, Chief Judge United States District Court Middle District of Pennsylvania

(Chief Judge Kane)


Pending before the Court is Defendants' motion to dismiss or, in the alternative, for summary judgment. (Doc. No. 14.) The motion has been fully briefed and is ripe for disposition. For the following reasons, the motion will be granted in part and denied in part.

I. Background*fn1

Plaintiff Laurie Snyder is a 47-year-old single mother of a sixteen-year-old daughter.

(Doc. No. 13 ¶¶ 1, 36.) From November 1, 1999, until she was terminated on March 2, 2009, Snyder was employed as an accountant in the Finance Department of Defendant Administrative Office of Pennsylvania Courts ("AOPC"). (Id. ¶¶ 1, 29.) The AOPC is a state agency of the Commonwealth of Pennsylvania. The individual defendants, David Kutz, Margaret Arris, Deb McDivitt, Mary Gillette, and R. Dean Stiteler, all had supervisory authority over Snyder as administrative personnel in either AOPC's finance or human resources departments. (Id. ¶¶ 23-27.)

In January 2008, Snyder suffered a major episode of depression, of which Defendants were aware. (Id. ¶ 47.) At that time, Defendants informed Snyder that they would be transferring her job duties to a temporary accountant. (Id. ¶ 48.) On January 23, 2008, Snyder complained to Arris, AOPC's Assistant Director of Human Resources, that she was the subject of a hostile work environment, and the two discussed Snyder's depression. (Id. ¶ 49.) Snyder also complained to Arris about the unequal treatment of women in the AOPC workplace and the negative treatment of single mothers like Snyder. (Id. ¶ 51.)

Despite Snyder's complaints, Defendants failed to investigate her concerns or take any remedial action. (Id. ¶ 50.) Instead, Snyder alleges that Defendants began retaliating against her for her complaints. This retaliation first occurred in February and March 2008, when Snyder's requests to attend a professional accounting conference and continuing education training were denied. (Id. ¶¶ 53-54.) Prior to her complaints, such requests by Snyder had been routinely granted. (Id. ¶ 55.) On April 21, 2008, Snyder requested to use three hours of leave on April 25, 2008, to help her grandmother who was in the hospital with a broken hip and was suffering from complications. (Id. ¶¶ 56-57.) The request was denied by Gillette and Stiteler, Snyder's supervisors in the Finance Department, even though Snyder had accrued leave time. (Id. ¶ 58.) Furthermore, Gillette and Stiteler made negative comments about Snyder's use of leave to care for family members. (Id. ¶ 59.)

On April 22, 2008, Snyder was called into her supervisor's office, given a list of job duties, and told that she needed to go over them with the newly-hired temporary accountant. (Id. ¶ 60.) That same day, Snyder's daughter began experiencing symptoms of what Snyder alleges was a "serious health condition." (Id. ¶ 61.) Snyder attended her daughter's appointment at Hershey Medical Center where she received a schedule for subsequent treatment of her daughter. (Id.)

On April 25, 2008, Snyder provided the schedule of her daughter's medical appointments to AOPC's human resources department and Arris and requested time off to care for her daughter. (Id. ¶ 64.) Snyder again told Arris about the harassment and scrutiny by her superiors and reiterated her concern that single mothers were discriminated against in the workplace. (Id. ¶ 65.) Defendants failed to investigate Snyder's complaints or take any remedial action. (Id. ¶ 66.) Additionally, Defendants did not offer leave to Snyder to care for her daughter under the Family Medical Leave Act ("FMLA"), 29 U.S.C. § 2601 et seq., or designate Snyder's absences to care for her daughter as FMLA leave. (Id. ¶¶ 2, 67.)

That same afternoon, Snyder was called into a meeting with Gillette and Stiteler, who told Snyder to act "professionally," to document every reason for her leave requests, and to list other employees who were off at her requested times. (Id. ¶ 69.) In addition, Gillette and Stiteler told Snyder that she was not allowed to discuss finance department issues with anyone from outside the department and that she should "keep her opinions to herself." (Id.) Following her meeting with Gillette and Stiteler, Snyder was afraid that she would be subjected to discipline for discussing leave with the human resources department. (Id. ¶ 70.) As a result, Snyder retrieved the schedule of her daughter's medical appointments from human resources. (Id.)

From August 2008 until October 2008, Snyder became subject to increased scrutiny by her supervisors, and her workload was gradually reduced. (Id. ¶¶ 72-83.) On October 30, 2008, Snyder met with Arris for the third time and told Arris that she was being discriminated against and harassed. (Id. ¶ 84.) Arris asked Snyder if she wanted to take some time off; however, Arris did not place Snyder on FMLA leave or advise her that such leave was available to her. (Id. ¶ 86.)

On October 31, 2008, Snyder attempted to log into work through her home remote access, but she found that the remote access had been disabled by Defendants pursuant to an instruction from Gillette. (Id. ¶¶ 87-88.) Snyder contacted AOPC Human Resources and again talked to Arris. (Id. at 89.) Snyder asked what was going on and explained that she felt like she was going to be fired. (Id.) Snyder stated that her "nerves were shot" and that she could not take the harassment or hostile environment anymore. (Id.) In response, Arris told Snyder to "do whatever she felt like she needed to do." (Id.) Arris did not advise Snyder of any right to take FMLA leave. (Id. ¶ 90.) However, after her conversation with Human Resources, Snyder met with her treating medical providers, who suggested that she use FMLA leave to care for her own serious health condition. (Id. ¶ 91.)

On November 1, 2008, Snyder contacted Thomas Darr, the Deputy Court Administrator of the Pennsylvania Courts, and requested assistance with the escalating hostility at work and the ongoing transfer of her job duties to other employees. (Id. ¶ 92.) Snyder also requested an accommodation for her depression. (Id.) Snyder did not receive a response from Darr. (Id. ¶ 93.) Snyder took leave for her own medical condition on or about November 3, 2008. (Id. ¶ 94.) She provided a note from her doctors recommending that she not work at that time due to her psychological state. (Id. ¶ 94.)

On December 23, 2008, Snyder returned to work after using six weeks of FMLA leave to care for her depression. (Id. ¶ 97.) Also in December 2008, Snyder submitted a written, internal complaint of discrimination. (Id. ¶ 95.) Defendants failed to take any remedial action or engage in any interactive process with Snyder. (Id. ¶ 96.) Instead, Snyder alleges that she was subjected to continued intimidation by Defendants. (Id. ¶¶ 98-99.)

On December 26, 2008, Snyder's grandmother passed away. (Id. ¶ 100.) Snyder took bereavement leave from December 29, 2008, until December 31, 2008. (Id.) Snyder returned to work on January 5, 2009. (Id. ¶ 101.) On January 13, 2009, Defendants gave Snyder a negative performance evaluation which Snyder alleges was further retaliation for complaining of discrimination and taking FMLA leave. (Id. ¶ 102.) Shortly after receiving the negative performance evaluation, Snyder resumed her approved FMLA leave for depression. (Id. ¶ 103.) She was scheduled to return on March 2, 2009. (Id.)

On February 25, 2009, prior to returning to work from her second leave, Snyder made a written request for accommodations from Defendants for her depression. (Id. ¶ 105.) On February 26, 2009, Kutz informed Snyder in writing that her request for accommodations would be forwarded to her department managers; however, no accommodation was provided. (Id. ¶¶ 106, 111.) On February 27, 2009, Snyder filed a formal complaint of discrimination and retaliation with the Pennsylvania Human Relations Commission ("PHRC") and the Equal Employment Opportunity Commission ("EEOC"). (Id. ¶ 104.)

On March 2, 2009, Snyder reported to work at the conclusion of her FMLA leave. (Id. ¶ 107.) Upon her arrival, Snyder was called into a meeting with McDivitt and Gillette, where she was terminated. (Id. ¶ 108.) Snyder filed her complaint in the above-captioned case on ...

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