Khula v. State Corr. Inst.-Somerset
145 A.3d 1209
| Pa. Commw. Ct. | 2016Background
- Khula was hired in 2005 by SCI‑Somerset as a Mechanical Trades/Drafting CAD vocational teacher; his job specification and a signed acknowledgement required obtaining/maintaining a Pennsylvania Vocational I teaching certificate as a condition of employment.
- He worked from 2005–2007 without a Vocational I certificate on an Intern certificate; he completed classroom requirements but repeatedly failed the Praxis exam required for certification.
- In 2011 SCI‑Somerset charged and then terminated Khula for failure to attain Vocational I Certification after PDC hearings; prior evaluations documented satisfactory job performance.
- After termination, psychological testing (May 2011) diagnosed learning disability/ADHD; testing allowed accommodations (extra time, private room) but Khula still failed the Praxis when retaking it with accommodations and could not afford further attempts while unemployed.
- AUnion grievance later converted the termination to a resignation with conditional reinstatement if Khula later obtained certification; Khula sued under the PHRA claiming disability discrimination and failure to accommodate; the trial court granted summary judgment to SCI‑Somerset, and the Commonwealth Court affirmed, with one judge dissenting.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Vocational I certification was an essential/job‑related requirement such that Khula was not a “qualified individual” | Khula: Certification not essential because he teaches only adults and position was structured to avoid school‑teacher certification requirements | SCI‑Somerset: Job specs, signed acknowledgement, and condition of employment make Vocational I certification required regardless of student age | Court: Certification was a job‑related/essential requirement; Khula was not qualified without it (affirmed) |
| Whether employer had duty to engage in interactive process / provide reasonable accommodation (e.g., preserve job, seek extension/waiver) | Khula: Employer should have maintained his job and worked with Civil Service or provided more time/assistance to secure accommodations for Praxis | SCI‑Somerset: Requested accommodation (extra time/private room) was controlled by test administrator, not employer; SCI‑Somerset paused discipline and allowed retakes; accommodations were later provided but he still failed | Court: No duty to provide or control the testing accommodations; employer satisfied interactive obligations and did not act in bad faith (affirmed) |
Key Cases Cited
- Taylor v. Phoenixville Sch. Dist., 184 F.3d 296 (3d Cir. 1999) (defines ADA prima facie elements and explains employer–employee interactive process for accommodations)
- Allen v. State Civil Serv. Comm’n, 992 A.2d 924 (Pa. Cmwlth. 2010) (PHRA ADA‑parallel framework and summary of Taylor)
- Canteen Corp. v. Pa. Human Relations Comm’n, 814 A.2d 805 (Pa. Cmwlth. 2003) (employer duty to engage in interactive process and assess good‑faith participation)
- Jennison Family Ltd. P’ship v. Montour Sch. Dist., 802 A.2d 1257 (Pa. Cmwlth. 2002) (summary judgment standard review on appeal)
- Borough of Blawnox Council v. Olszewski, 477 A.2d 1322 (Pa. 1984) (civil service removals must be job‑related and tied to competency)