HOUPT v. MYZAK HYDRAULICS, INC.
2:13-cv-00559
W.D. Pa.Jan 22, 2015Background
- Plaintiffs Christine Pifer and Cheryl Houpt were employees of Myzak Hydraulics, Inc. with Joseph Myzak as president/CEO.
- They filed EEOC charges in 2012 and requested dual filing with the PHRC; EEOC issued right-to-sue letters on March 6, 2013.
- Pifer filed suit March 26, 2013; Houpt filed April 18, 2013; amended complaints allege Title VII and PHRA claims against Myzak and state torts against Mr. Myzak.
- The court consolidated for discovery purposes and later addressed partial summary judgment and consolidation for trial.
- The court held dual filing exhausted PHRA remedies under the EEOC/PHRC work-sharing framework and provisionally denied IIED claims, granting negligence claims by stipulation and consolidating for trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Pifer and Houpt exhausted PHRA remedies | Pifer/Houpt dual-filed via work-share agreement | PHRC filing required within 180 days or specific dual-file actions | Exhaustion satisfied; PHRA claims survive |
| IIED claims against Mr. Myzak individual capacity | IIED supported by intensely abusive conduct; not barred by WCA | WCA §72 may bar IIED against employer/owner relationship | IIED claims not barred at this stage; proffer of physical injury required; can be renewed at trial |
| Negligence claims | Not opposed; actionable negligence present | Negligence claims should be dismissed | Granted in favor of defendants by stipulation |
| Consolidation for trial | Separate trials to avoid confusion and prejudice | Consolidation efficient due to common facts | Cases consolidated for trial |
Key Cases Cited
- Woodson v. Scott Paper Co., 109 F.3d 913 (3d Cir. 1997) (dual filing under work-sharing agreement may satisfy PHRA exhaustion)
- Hoy v. Angelone, 720 A.2d 745 (Pa. 1998) (IIED requires extreme conduct; retaliation not mandatory)
- Reedy v. Evanson, 615 F.3d 197 (3d Cir. 2010) (high bar for IIED; outrageous conduct with physical impact may reach standard)
- Yeager v. UPMC Horizon, 698 F. Supp. 2d 523 (W.D. Pa. 2010) (dual filing, PHRA exhaustion considerations under work-sharing)
- Barb v. Miles, Inc., 861 F. Supp. 356 (W.D. Pa. 1994) (context of IIED in workplace harassment)