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Emma Miller v. Tyco Electronics

November 14, 2012

EMMA MILLER, PLAINTIFF
v.
TYCO ELECTRONICS, LTD., DEFENDANT



The opinion of the court was delivered by: (Chief Judge Kane)

MEMORANDUM ORDER

Before the Court are seven motions in limine: two filed by Plaintiff Emma Miller (Doc. Nos. 55, 57), and five filed by Defendant Tyco Electronics (Doc. Nos. 59-63). The motions are ripe for disposition.

I. BACKGROUND

Plaintiff worked in various manufacturing and assembly capacities on production lines while employed by Defendant Tyco from 1999 until she was terminated in March 2009. In 2007, Plaintiff was transferred from a plant in East Berlin, Pennsylvania to a plant in Harrisburg. In November 2008, Plaintiff's new supervisor James Smith gave Plaintiff a poor performance evaluation, noting that her skills did not measure up to the descriptions of her job classification. Plaintiff complained to Tyco's human resources department, asserting that Mr. Smith discriminated against her and harassed her because of her gender and national origin. Tyco's human resources department determined that she did not suffer any unlawful discrimination. When Tyco engaged in a reduction in force in March 2009, Plaintiff was formulaically chosen for layoff because she had previously received a poor performance evaluation.

Plaintiff initiated this action by filing a complaint on December 3, 2010, alleging that she was terminated from her position at Tyco for improper reasons. (Doc. No. 1.) At the time that she filed her complaint, Plaintiff's discrimination claim with the Pennsylvania Human Relations Commission (PHRC) was still pending. (Id. ¶ 10.) On December 14, 2010, the PHRC informed Plaintiff of its finding that the evidence supporting her claims was not sufficient to show an unlawful act of discrimination. Plaintiff filed an amended complaint against Tyco on January 17, 2012, raising claims under Title VII of the Civil Rights Act of 1964, the Equal Pay Act, the Americans with Disabilities Act, and the Pennsylvania Human Relations Act (PHRA), alleging that she was terminated based on, inter alia, her gender, national origin, and race. (Doc. No. 4.) Specifically, Plaintiff asserts that Mr. Smith gave her a poor performance evaluation so that she would be laid off, and that his discriminatory animus toward her gender and national origin were motivating factors in his decision to give her a poor performance evaluation. In support, Plaintiff claims that Mr. Smith told her that no woman should be doing the type of work that she was performing, screamed at her for wearing jewelry, called her dumb, tried to flick her in the head, laughed at her Filipino accent, and called her a "dumb Filipino."

On November 23, 2011, the Court denied Defendant's first motion for summary judgment, in which Defendant argued that Plaintiff had waived her right to file the instant suit by agreeing to a release of her workers' compensation claim against Tyco. (Doc. No. 29.) The Court found that a handwritten amendment to the release may have preserved Plaintiff's discrimination claims. (Id.) On July 11, 2012, Plaintiff filed a stipulation amending her complaint, dropping all of her claims except for a Title VII claim and a PHRA claim based on gender and national origin. (Doc. No. 36.) Following discovery, Defendant filed a second motion for summary judgment, arguing that Plaintiff failed to present sufficient evidence to support her discrimination claims. (Doc. No. 39.) On September 18, 2012, the Court denied Defendant's second motion for summary judgment, finding that she presented sufficient evidence to support a finding of discrimination by Mr. Smith. (Doc. No. 54.)

II. PLAINTIFF'S MOTIONS

Plaintiff filed two motions in limine: first, Plaintiff seeks to preclude any documents and evidence pertaining to the Pennsylvania Human Relations Commission's (PHRC) finding of no probable cause on Plaintiff's charge of discrimination (Doc. No. 57); second, Plaintiff seeks to preclude evidence related to her workers' compensation settlement proceeds (Doc. No. 55). For the reasons that follow, the Court will grant the first motion, and deny the second motion.

A. The PHRC's Findings

First, Plaintiff moves to preclude Defendant from presenting the PHRC's findings and the letter advising the parties that the PHRC found no probable cause on Plaintiff's charge of discrimination. (Doc. No. 57.) Specifically, Plaintiff argues that the evidence should be excluded pursuant to Rule 403 of the Federal Rules of Evidence. (Doc. No. 58.)

"'Relevant evidence' means evidence having any tendency to make the existence of any fact that is of consequence to the determination of the action more probable or less probable than it would be without the evidence." Fed. R. Evid. 401. "All relevant evidence is admissible." Fed. R. Evid. 402. However, relevant evidence "may be excluded if its probative value is substantially outweighed by the danger of unfair prejudice, confusion of the issues, or misleading the jury." Fed. R. Evid. 403. The United States Court of Appeals for the Third Circuit has explained that "the decision of whether or not an EEOC Letter of Determination is more probative than prejudicial is within the discretion of the trial court, and to be determined on a case-by-case basis." Coleman v. Home Depot, Inc., 306 F.3d 1333, 1345 (3d Cir. 2002).

Logically, this holding applies with equal force to findings of the PHRC, which is the state analogue to the EEOC.

Defendant argues that the probative value of the PHRC findings outweigh any concerns that the evidence will be given any undue weight. (Doc. No. 89.) Defendant also argues that the PHRC's findings are relevant with respect to Plaintiff's prayer for punitive damages as the evidence rebuts any claim that Defendant had malicious intent. (Id. at 5-6.) While the PHRC's findings of no probable cause are relevant, the evidence creates an undue risk of prejudice and delay. The PHRC's findings are not binding on the jury, and Defendant will be able to present the evidence at trial that supported the PHRC's findings. Therefore, Defendant will not be prejudiced by the exclusion of this evidence. Conversely, Plaintiff is likely to be unfairly prejudiced by the evidence that a governmental body found that there was no probable cause of her charges of discrimination. Whether Plaintiff suffered unlawful discrimination and whether Plaintiff is entitled to punitive damages are issues within the province of the jury, not the PHRC. Moreover, presentation of the PHRC's findings would create an undue delay at trial and confuse the issues. See Sarin v. Poojan, Inc., No. 3:08-cv-1077, 2010 WL 5463250, at *6 (M.D. Pa. Dec. 29, 2010) (granting defendant's motion in limine, finding that the PHRC's findings of probable cause were unduly prejudicial to the defendant and would needlessly waste time); Supinski v. UPS, No. 3:06-cv-793, 2012 WL 2905381, at *9 (M.D. Pa. July 16, 2012) (denying motion for new trial, noting that "PHRC findings were excluded because of fear that a jury would give undue weight to the decisions of a government agency"); Cambra v. Rest. Sch., No. Civ. A 04-2688, 2005 WL 2886220, at *5 (E.D. Pa. Nov. 2, 2005) (excluding EEOC letter as cumulative and likely to confuse and mislead the jury).

Thus, the Court will grant Plaintiff's motion to preclude evidence related to the PHRC's findings of no probable cause.

B. Plaintiff's Workers' Compensation Settlement

In Plaintiff's second motion in limine, she argues that the Court should preclude Defendant from arguing that her workers' compensation settlement proceeds should be offset against any potential lost wages awarded to her discrimination action. (Doc. No. 55.) Specifically, Plaintiff asserts that Title VII and the PHRA do not specifically allow an offset for payment of workers' compensation benefits, and the collateral benefit rule prohibits Defendant from offsetting its liability. (Doc. No. 56 at 3-4.) Moreover, Plaintiff asserts that while other district courts in the Third Circuit have ...


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