B.D. Goodall v. PA DOC
153 C.D. 2024
Pa. Commw. Ct.May 23, 2025Background
- Brenda D. Goodall worked at the State Correctional Institution at Mercer and experienced debilitating migraines, for which she took FMLA intermittent and paid leave.
- Goodall alleged her supervisor pressured her to return to work and, upon her return, imposed a preapproval requirement for future leave because FMLA leave was exhausted.
- Goodall contended the preapproval was unattainable for her due to the unpredictability of her migraines, causing her to retire early (constructive discharge).
- Goodall claimed hostile work environment and disability discrimination under the PHRA and retaliation under the FMLA against the Pennsylvania Department of Corrections.
- The trial court granted summary judgment for the Department, finding no severe or pervasive harassment, adverse action, or failure to reasonably accommodate.
- Goodall appealed, contesting the application of law and factual findings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Hostile work environment under PHRA | Graves created a hostile environment via pressure and leave restrictions | Graves' actions were minimal, consistent with policy | No severe/pervasive harassment; claim fails |
| Constructive discharge under PHRA | Preapproval policy made resignation only choice | No intolerable conditions; no forced resignation | Work conditions not intolerable; no constructive discharge |
| FMLA retaliation | Preapproval and pressure amounted to retaliation for leave usage | Requirement was policy, never enforced or disciplined | No adverse action or retaliation; claim fails |
| Reasonable accommodation of disability | Department failed to reasonably accommodate migraines | Department accommodated, imposed only standard policies | Reasonable accommodation provided; claim fails |
Key Cases Cited
- Infinity Broad. Corp. v. Pa. Hum. Rels. Comm'n, 893 A.2d 151 (Pa. Cmwlth. 2006) (outlines elements of hostile work environment under PHRA)
- Raya & Haig Hair Salon v. Pa. Hum. Rels. Comm'n, 915 A.2d 728 (Pa. Cmwlth. 2007) (standard for constructive discharge – intolerable work conditions)
- Brown-Boyd v. Se. Pa. Transp. Auth., 320 A.3d 872 (Pa. Cmwlth. 2024) (summary judgment: no genuine dispute of material fact, legal standard)
- Howarth v. Falls Twp., 310 A.3d 336 (Pa. Cmwlth. 2024) (standard for reviewing summary judgment—view in light most favorable to non-movant)