Godwin v. The George Wash., LP

• Decision Date: 30 December 2022
• Docket Number: Civil Action 22-1066
• Parties: JEANNA GODWIN Plaintiff, v. THE GEORGE WASHINGTON, LP, Defendant.
• Court: U.S. District Court — Western District of Pennsylvania

JEANNA GODWIN Plaintiff,
v.
THE GEORGE WASHINGTON, LP, Defendant.

Civil Action No. 22-1066

United States District Court, W.D. Pennsylvania

December 30, 2022

MEMORANDUM OPINION

PATRICIA L. DODGE, UNITED STATES MAGISTRATE JUDGE

Plaintiff Jeanna Godwin (“Godwin”) alleges that she was discriminated against on the basis of a disability or perceived disability when an offer of employment was withdrawn by Defendant The George Washington, LP after it learned that she was on a methadone maintenance treatment program.

Presently pending before the Court is Defendant's partial motion to dismiss the request for punitive damages in the Second Amended Complaint (ECF No. 13). For the reasons that follow, the motion will be denied.^[1]

I. Relevant Procedural Background

Godwin commenced this action on July 26, 2022 and filed an Amended Complaint on October 3, 2022 (ECF No. 11). Count I alleged disability discrimination in violation of the Americans With Disabilities Act, 42 U.S.C. §§ 12101-12117 (ADA), and Count II asserted the same allegations under the Pennsylvania Human Relations Act, 43 P.S. §§ 951-63 (PHRA). Federal question jurisdiction was asserted over the ADA claim, 28 U.S.C. § 1331, and supplemental jurisdiction is asserted over the state law claim, 28 U.S.C. § 1367(a).

1

On October 17, 2022, Defendant filed a partial motion to dismiss (ECF No. 13), seeking both to dismiss the request for punitive damages in Count I and the PHRA claim on the ground that it is premature. The motion has been fully briefed (ECF Nos. 14, 20). Defendant filed an answer to the other allegations in the Amended Complaint (ECF No. 15).

At the Initial Case Management Conference on November 15, 2022, the parties reached a compromise in which Godwin agreed to file a Second Amended Complaint (“SAC”) on or after November 29, 2022, at which time the PHRA claim would be timely, and Defendant's motion would be considered only if the SAC still contained a request for punitive damages.

On December 2, 2022, Godwin filed the SAC, which still includes a request for punitive damages.^[2] Therefore, the Court will address Defendant's motion to dismiss as to that issue only.

A. Facts Alleged in the Second Amended Complaint

Godwin alleges that she has been prescribed a methadone maintenance program for several years with no issue nor relapses. On or about August 3, 2021, Defendant contacted her with regard to an application for employment she had submitted. At that time, Defendant extended an offer of employment as a banquet bartender for its Washington, Pennsylvania location. (SAC ¶¶ 9-11.) Godwin had been referred to apply for this position by a longtime employee of the Defendant and has over twenty years of serving and bartending...