Long v. Spalding Auto. Inc.
337 F. Supp. 3d 485
E.D. Pa.2018Background
- Plaintiff, a production welder, alleged disability and race discrimination, retaliation, and FMLA violations by his employer after periods of back/thoracic pain, medical leaves, and attendance-point additions.
- Plaintiff provided medical notes requesting light duty and short-term disability in Sept–Oct 2015; employer said no light duty was available and required full-duty capability to return.
- Plaintiff made internal discrimination complaints in April 2015 and filed EEOC charges in Dec 2015 and Nov 2016 after attendance points and termination.
- Plaintiff sought and was later approved for FMLA leave in mid-2016; employer claimed it never received his FMLA medical certification and terminated him on August 1, 2016 for an unacceptable attendance record.
- Procedural posture: Employer moved to dismiss under Rule 12(b)(6); court evaluated sufficiency of claims under ADA, ADA-retaliation, FMLA-retaliation, 42 U.S.C. § 1981, and the Pennsylvania Human Rights Act (PHRA).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ADA disability discrimination | Plaintiff alleges he suffered thoracic and lumbar conditions and was denied reasonable accommodation (light duty) | Employer argues medical records show only temporary restrictions, not an ADA-qualifying disability | Dismissed without prejudice; plaintiff failed to plead a substantial, ongoing impairment but may amend |
| ADA retaliation | Plaintiff says he was retaliated against for requesting accommodations/leave | Employer points to long time gap and lack of causal link between request and termination | Dismissed without prejudice; nine-month gap not unusually suggestive of causation absent pattern of antagonism |
| FMLA retaliation | Plaintiff contends termination followed his June 2016 FMLA request and that he timely submitted medical certification | Employer contends plaintiff failed to provide required FMLA documentation and thus leave was unauthorized | Survives 12(b)(6); proximate timing (≈1 month) and plaintiff's allegations that he sent certification state a plausible claim |
| § 1981 and PHRA race/national-origin claims | Plaintiff alleges denial of leave to travel to Vietnam and disparate treatment | Employer notes absence of any factual allegations tying adverse actions to race or any racial allegations in internal/EEOC complaints | Dismissed without prejudice for lack of factual support; leave to amend granted |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for pleadings)
- Macfarlan v. Ivy Hill SNF, LLC, 675 F.3d 266 (temporary restrictions not ADA disability)
- Shaner v. Synthes, 204 F.3d 494 (elements of ADA discrimination claim)
- Lichtenstein v. Univ. of Pittsburgh Med. Ctr., 691 F.3d 294 (FMLA retaliation standard compared to ADA)
- Marra v. Philadelphia Hous. Auth., 497 F.3d 286 (retaliation standards under federal employment laws)
- Burlington Indus., Inc. v. Ellerth, 524 U.S. 742 (definition of adverse employment action)