Baughman v. Marathon Petroleum Logistics Services, LLC
4:24-cv-00287
| M.D. Penn. | Feb 13, 2025Background
- Danielle Baughman sued Marathon Petroleum Logistics Services, LLC and Marathon Petroleum Corporation, alleging workplace sex discrimination, hostile work environment, and retaliation in violation of Title VII, the PHRA, and the FMLA.
- Baughman claims repeated discriminatory comments and adverse actions from supervisor Steven Smith and other male colleagues, including removal from valued assignments and forced assistance to less-qualified male employees.
- Baughman experienced anxiety and depression due to the alleged discrimination, leading her to take periods of medical leave and to file administrative complaints with the PHRC and the EEOC.
- Upon return from medical leave, Baughman alleges she was reassigned to inferior positions, was not provided training, and continued to face unreasonable tasks and deadlines.
- She maintained that Defendants failed to address her complaints or provide accommodations and ultimately terminated her employment.
- Defendants moved to dismiss on grounds of improper venue and failure to state a claim; the court denied the motion, allowing the case to proceed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Venue Properness (Title VII) | Middle District is proper as it is within PA where alleged conduct occurred | Venue improper; all acts occurred in Pittsburgh, outside Middle District | Venue proper per Title VII provision |
| Sufficiency of Title VII/PHRA Claims | Alleged specific instances & timing of discrimination, hostile environment | No concrete adverse action or discrimination; some claims time-barred | Claims sufficiently pled |
| Hostile Work Environment | Alleged pervasive pattern by male supervisors, not isolated incidents | Allegations not severe/pervasive enough; acts are time-barred or insufficiently pled | Sufficient to state a claim |
| Continuing Violation Doctrine | Pattern of conduct forms a continuing violation into limitations period | Discrete acts time-barred, doctrine does not apply | Doctrine applies at this stage |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards for sufficiency of allegations)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (standard for plausibility in complaints)
- Harris v. Forklift Sys., Inc., 510 U.S. 17 (standard for hostile work environment under Title VII)
- Faragher v. City of Boca Raton, 524 U.S. 775 (employer liability for supervisor harassment)
- Burlington Industries, Inc. v. Ellerth, 524 U.S. 742 (tangible employment action for vicarious employer liability)
- Storey v. Burns Int’l Sec. Servs., 390 F.3d 760 (adverse employment action standard under Title VII)
- Stebbins v. State Farm Mut. Auto. Ins. Co., 413 F.2d 1100 (Title VII venue provision and intent)