Slayton v. Sneaker Villa, Inc.
| Decision Date | 20 March 2017 |
| Docket Number | CIVIL ACTION No. 15-0074 |
| Parties | NADIA SLAYTON, Plaintiff, v. SNEAKER VILLA, INC., Defendant. |
| Court | U.S. District Court — Eastern District of Pennsylvania |
MEMORANDUM OPINION
This case involves claims of disability discrimination. Plaintiff, Nadia Slayton, alleges that Defendant, Sneaker Villa, Inc., unlawfully terminated her employment in violation of the Americans with Disabilities Act ("ADA"), 42 U.S.C. §§ 12101, et seq., and the Pennsylvania Human Relations Act ("PHRA"), 42 P.S. § 951, et seq. Plaintiff claims that Sneaker Villa discriminated against her based on her disability, failed to provide a reasonable accommodation, and retaliated against her for requesting a reasonable accommodation. Presently before me is Sneaker Villa's motion for summary judgment. For the reasons that follow, the motion will be granted only regarding Plaintiff's request for punitive damages on her retaliation and state law claims, but will be denied in all other respects.
The following facts are undisputed, unless otherwise noted.
Plaintiff began working for Defendant as a Corporate Recruiter on November 14, 2012. On February 2, 2013, approximately eighty (80) days into her employment, Plaintiff was seriously injured in a bus accident and hospitalized for five (5) days, suffering compression fractures of multiple vertebrae in her neck and back, and sustaining a head injury. (Def.'s SOF ¶¶ 23, 27, 29, 30.)
On February 4, 2013, Plaintiff's sister emailed Plaintiff's supervisor, Denise Lee (Director of Human Resources), and apprised her of the accident and Plaintiff's physical condition. Plaintiff was given an application to collect Short Term Disability benefits during her absence from work. During Plaintiff's roughly two-month unpaid absence, Defendant hired a temporary employee to cover the responsibilities of the Corporate Recruiter position. (Def.'s SOF ¶¶ 27, 31-33, 36; Def.'s Ex. K; Denise Lee Dep. 202:2-11.)
On March 28, 2013, Plaintiff emailed Denise Lee requesting the "reasonable accommodation of working full time from home for the next four weeks or until my physical therapy is complete and [my doctor] releases me back to full time status without restrictions." (Def.'s Ex. N.) Plaintiff indicated that her physical restrictions included, inter alia, no driving, no lifting anything heavier than five pounds, no bending or walking, and no sitting or standing for long periods of time. (Id.)
On April 1, 2013, Denise Lee responded to Plaintiff's email stating in relevant part:
Plaintiff replied to Denise Lee's email that same day and asked her to reconsider. Specifically, Plaintiff stated she was:
... requesting the accommodation to work full time from home only for a maximum of 4 weeks. This accommodation could expedite my physical therapy and possibly make my return to the office sooner. Another option would be to work part time in the office approximately 10-15 hours per week and the other 25-30 hours from home which is 40 hours per week until my physical therapy is complete. I can perform all of the essential functions of the duties you listed at home with the exception of the job fairs which I may need a minor accommodation. Posting and monitoring the job descriptions, interviewing, supporting store openings, and other duties assigned require a computer with an internet connection, phone with long distance, and account access with logons all of which I have. Please let me know your thoughts as soon as possible.
(Id.) (emphasis in original).
On April 2, 2013, the next day, Plaintiff went to Defendant's Philadelphia office. The parties dispute what prompted Plaintiff's visit. According to Plaintiff, she called Denise Lee and asked to come in for a meeting to discuss her employment with Defendant, and Lee allegedly agreed to meet. Plaintiff claims she met with Lee in her office, and Lee informed her that her employment was being terminated. Plaintiff further claims that she was asked to turn in her company property. (Pl.'s Dep. 242:6-24; 243:19-23.)
According to Denise Lee, there was no meeting scheduled between the two, and they merely exchanged a brief greeting in passing at the office. (Lee Dep. 148:1-16.) The parties do not dispute that Plaintiff turned in her company key card and employee discount card before she left Defendant's building on April 2. (Def.'s SOF ¶ 52.)
On April 8, 2013, Denise Lee emailed Plaintiff requesting a doctor's note outlining her restrictions so that a "formal decision may be made on [her] continued employment." (Def.'s Ex.N.) Plaintiff responded that she "thought a formal decision was made regarding [her] employment in [Lee's] office last Tuesday [April 2] that [she] was indeed terminated." (Id.) Nevertheless, Plaintiff agreed to send a copy of her doctor's note. (Id.)
On April 14, 2013, Plaintiff emailed Denise Lee stating that there had been a miscommunication with her doctor's staff, which is why a note had still not been produced. (Def.'s Ex. N.) On April 15, 2013, Plaintiff emailed a doctor's note to Denise Lee, but less than a half hour later, told Lee to disregard it, and instructed that a new note would be sent momentarily. (Def.'s Ex. O.)
On April 16, 2013, the next day, Denise Lee emailed Plaintiff stating that because she had still not received a "return to work document" from Plaintiff's doctor, Lee had "no choice but to terminate [her] employment effective April 16, 2013." (Id.) Lee also stated there would be new positions in the human resources department opening up in the ensuing months, and Plaintiff should "feel free" to apply. Lee concluded by saying, "I regret this action but I must fill this position immediately." (Id.)
Plaintiff responded just over an hour later stating that she was "baffled" by Lee's email. Plaintiff pointed out that she believed her employment was terminated on April 2, 2013—the day she visited Defendant's office. Plaintiff also stated that she had sent a doctor's note the day before (April 15), and would have another copy faxed to Lee directly from the doctor so that there would be "no mistake about receiving the note." (Def.'s Ex. O.) Later that same day, Plaintiff again emailed Lee asking her to respond to Plaintiff's email, and to "let [Plaintiff] know what accommodations can be made." Plaintiff further requested that Lee let Plaintiff know as soon as possible if her termination stood effective, so that Plaintiff could "know what actions" to take on her end. (Id.)
Lee's reply email indicated that, although she did receive the doctor's note that day, the note stated that Plaintiff was only available to work 20 hours per week in the office (or full-time from home), and Defendant's needs were for a "full-time position in the office." Lee reiterated that Defendant was undergoing "tremendous growth," which required face-to-face interviews, traveling, attendance at job fairs, "and other responsibilities" that Plaintiff could not perform given her physical condition. (Id.; Def.'s Ex. Q.)
Plaintiff again replied and expressed confusion about Lee's message. Plaintiff indicated that her restrictions did not limit her "ability to interview, travel, or attend job fairs." Plaintiff reiterated that she could have worked twenty hours in the office and the other twenty at home, and that her accommodations were only temporary (i.e., her physical restrictions would be "lifted" in another two weeks). Nevertheless, Plaintiff acknowledged that these issues had already been discussed, so the "issue [was] dead." (Id.)
Plaintiff filed her Amended Complaint on January 12, 2015 alleging: disability discrimination; failure to accommodate; and, retaliation. (Am Compl. ¶¶ 41-66.) After a period of discovery, Defendant filed a motion for summary judgment on all of Plaintiff's claims.1 The motion has been fully briefed, and is now ripe for consideration.
A party moving for summary judgment bears the initial burden of demonstrating that there are no genuine issues of material fact in dispute, and that judgment is appropriate as a matter of law. Fed. R. Civ. P. 56(a); Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). Once a properly supported motion for summary judgment has been made, the burden shifts to the non-moving party, who must set forth specific facts showing that there is a genuine issue of material fact for trial. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 250 (1986).
An issue is "genuine" if a reasonable jury could rule in favor of the non-moving party based on the evidence presented. Kaucher v. Cnty. of Bucks, 455 F.3d 418, 423 (3d Cir. 2006). A factual dispute is "material" if it might affect the outcome of the suit under the appropriate governing law. Id. at 423. The non-moving party cannot avert summary judgment with speculation or conclusory allegations, but rather must cite to the record. Ridgewood Bd. of Educ. v. N.E. for M.E., 172 F.3d 238, 252 (3d Cir. 1999); Fed. R. Civ. P. 56...
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