Joanie Alston v. Park Pleasant Inc
679 F. App'x 169
| 3rd Cir. | 2017Background
- Alston was hired as Director of Nursing at Park Pleasant in Aug. 2011; performance issues arose after her supervisor changed in Feb. 2012.
- In June 2012 Park Pleasant placed Alston on an improvement plan; she took leave five days later for a biopsy and was diagnosed with early-stage DCIS (breast cancer) on July 12, 2012.
- Park Pleasant continued to criticize Alston and terminated her in early August 2012.
- Park Pleasant later sold its business and turned over some infrastructure; it retained documents it deemed potentially relevant and did not preserve all materials plaintiffs later sought in 2014 discovery.
- Alston sued under the ADA and PHRA alleging disability discrimination; the District Court granted summary judgment to Park Pleasant and denied Alston’s spoliation sanctions motion; Alston appealed only the ADA disability ruling and the sanctions denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Alston’s DCIS qualifies as a “disability” under the ADA (prima facie element) | DCIS as cancer is a qualifying impairment and Alston argued a cancer diagnosis (including remission) suffices | Park Pleasant argued Alston produced no evidence DCIS substantially limited any major life activity, so she is not disabled under ADA §12102 | Held: No. Alston failed to show any substantial limitation; summary judgment affirmed |
| Whether Park Pleasant engaged in spoliation of evidence warranting sanctions | Alston argued Park Pleasant failed to preserve potentially relevant stored data and withheld evidence | Park Pleasant showed it disclosed the situation, offered alternatives, and did not act in bad faith; plaintiff failed to pursue available discovery remedies | Held: No spoliation sanctions. Denial affirmed |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for discrimination claims)
- Gaul v. Lucent Technologies, Inc., 134 F.3d 576 (elements of ADA prima facie case)
- Albertson’s, Inc. v. Kirkingburg, 527 U.S. 555 (need for individualized evidence of substantial limitation)
- Colwell v. Rite Aid Corp., 602 F.3d 495 (requiring plaintiff-specific evidence of limitation)
- Bull v. United Parcel Serv., Inc., 665 F.3d 68 (spoliation factors and bad-faith requirement)
- Oehmke v. Medtronic, Inc., 844 F.3d 748 (post-ADAAA recognition that cancer can qualify as a disability)