Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Stahl v. Susque View Home Nursing and Rehabilitation Center

United States District Court, M.D. Pennsylvania

June 21, 2019

NICHOLE STAHL, Plaintiff,
v.
SUSQUE VIEW HOME NURSING AND REHABILITATION CENTER, Defendant.

          ORDER

          Matthew W. Brann, United States District Judge.

         On January 3, 2017, Nichole Stahl was fired from her job at the Susque View Home Nursing and Rehabilitation Center. In response, Ms. Stahl sued Susque View, arguing that her termination violated the Americans with Disabilities Act (Count I); the Family and Medical Leave Act (Count II); and Title VII of the Civil Rights Act of 1964 (Count III). Susque View now moves to dismiss Ms. Stahl's FMLA and Title VII claims. That motion will be denied.

         Background

         On August 1, 2016, while working at Susque View, Ms. Stahl requested “intermittent” FMLA leave in order attend medical appointments related to her pregnancy.[1] On August 31, 2016, Suque View informed her that she would be required to take a full-time leave of absence until she delivered the baby, which was due in March 2017.[2]

         Ms. Stahl unfortunately lost her child due to medical complications.[3] In mid-October, Ms. Stahl requested to remain out of work until December 5, 2016, in order to deal with those complications.[4] At the end of November 2016, Ms. Stahl asked to extend that leave until December 28, 2016.[5] Sometime later, Ms. Stahl asked for another leave extension, this time until January 16, 2017.[6] Susque View denied this request, and told Ms. Stahl that she had to return to work on December 30, 2016.[7]

         On December 23, 2016, Ms. Stahl notified Susque View of a hysterectomy that she underwent on December 14, 2016, and indicated that she was unable to return to work immediately.[8] Susque View consequently terminated her on January 3, 2017, and this lawsuit followed.

         Discussion

         FMLA Interference Claim

         Susque View argues that Ms. Stahl's FMLA interference claim fails as a matter of law because: (1) the FMLA guarantees only twelve workweeks of leave;[9](2) the period between August 31, 2016, and January 3, 2017-i.e., the period during which Ms. Stahl was on unpaid leave-exceeds twelve weeks; and (3) Susque View, therefore, did not deprive Ms. Stahl of any rights to which she was entitled under the FMLA.[10] This Court disagrees. While Ms. Stahl was clearly away from work for more than twelve weeks, this Court can-and therefore must-infer (1) that Susque View was utilizing a calendar year method of calculating FMLA leave;[11] (2) that Ms. Stahl was, therefore, entitled to twelve more weeks of FMLA leave in 2017, despite exhausting her 2016 benefits; and (3) that Susque View plausibly interfered with her right to take that leave.[12] Ms. Stahl's FMLA interference claim, therefore, survives.

         FMLA Retaliation Claim

         Susque View argues that Ms. Stahl's FMLA retaliation claim fails as a matter of law because Ms. Stahl failed to allege a causal link between her invocation of her FMLA rights and her termination.[13] This Court disagrees. As noted above, this Court must construe Ms. Stahl's December 23, 2016 communication to Susque View as, in part, a request for 2017 FMLA leave. If the timing of her termination eleven days later is not “unduly suggestive”[14] on its own, a reasonable jury could, in light of the other circumstances alleged (including Ms. Stahl's extensive medical leave in 2016), find that her termination was done to retaliate against her for asserting her FMLA rights. Ms. Stahl's FMLA interference claim, therefore, survives.

         Pregnancy Discrimination Claim

         Susque View argues that Ms. Stahl's pregnancy discrimination claim fails as a matter of law because Ms. Stahl failed to allege a causal link between her invocation of her FMLA rights and her termination.[15] This Court disagrees. On December 23, 2016, Ms. Stahl notified Susque View that she was unable to return to work because of a recent hysterectomy, which procedure was needed because of medical complications arising from her unsuccessful pregnancy.[16] Eleven days later, she was fired. That close temporal proximity, combined with the fact that Susque View responded to Ms. Stahl's request for intermittent pregnancy-related medical leave by requiring her to take full-time leave, would-if proven-allow a reasonable jury to find that Susque View was discriminating against Ms. Stahl on the basis of her pregnancy-related medical condition. Her Title VII claim, therefore, survives.

         D ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.