Cecelia Tierney v. Geisinger System Services, 20-3327

Tierney suffered a traumatic brain injury in 2000 and received Social Security disability; she worked intermittently and through vocational programs thereafter.
From 2013 she volunteered in Geisinger’s Wilkes-Barre gift shop as part of a Mature Workers Program; the program paid her though Geisinger considered her a volunteer.
In 2016 Geisinger posted part-time retail associate openings; Tierney apparently applied (she does not recall doing so) but was not interviewed or hired.
Tierney sued under the ADA, ADEA, and PHRA alleging failure to hire based on disability and age; the District Court granted summary judgment for Geisinger.
Geisinger proffered a legitimate, nondiscriminatory reason: Tierney could not perform essential job functions (e.g., the new computerized inventory system); Tierney offered only isolated statements and no evidence of pretext.
The Third Circuit affirmed, assuming arguendo a prima facie case but holding Tierney failed to show Geisinger’s reasons were pretextual.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Prima facie showing of discrimination (ADEA/ADA/PHRA)	Tierney: she is in protected classes, was qualified, and suffered an adverse hiring decision	Geisinger: she lacked qualification to perform essential functions	Court: assumed prima facie for argument's sake but resolved case on pretext; not necessary to decide definitively
Whether Geisinger’s nondiscriminatory reason was pretextual	Tierney: supervisor statements and other isolated facts show discrimination	Geisinger: offered legitimate reason (inability to perform essential duties like computerized inventory); plaintiff produced no evidence undermining it	Court: plaintiff failed to show weaknesses or contradictions sufficient to raise a genuine dispute of material fact; summary judgment affirmed

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (established burden‑shifting framework for disparate‑treatment claims)
Fuentes v. Perskie, 32 F.3d 759 (3d Cir. 1994) (standard for proving pretext under McDonnell Douglas)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment: no genuine dispute if reasonable factfinder could not find for nonmoving party)
Minarsky v. Susquehanna Cnty., 895 F.3d 303 (3d Cir. 2018) (standard of review for summary judgment appeals)
Newman v. GHS Osteopathic, Inc., 60 F.3d 153 (3d Cir. 1995) (applying McDonnell Douglas framework to ADA/ADEA contexts)
Fuentes v. Perskie, 32 F.3d 759 (3d Cir. 1994) (pretext showing requires demonstrating significant inconsistencies or implausibilities)
Turney v. Hershey Chocolate USA, 440 F.3d 604 (3d Cir. 2006) (ADA prima facie framework)
Narin v. Lower Merion School Dist., 206 F.3d 323 (3d Cir. 2000) (ADEA prima facie framework)
Keller v. Orix Credit Alliance, Inc., 130 F.3d 1101 (3d Cir. 1997) (affirming resolution at pretext stage without deciding prima facie)
Kelly v. Drexel Univ., 94 F.3d 102 (3d Cir. 1996) (PHRA often interpreted consistently with federal anti‑discrimination statutes)