Prelich v. Medical Resources, Inc., 813 F. Supp. 2d 654

Amanda Prelich, MR Technologist at Colonnade Imaging Center (MRI), learned she was pregnant and sought accommodations.
MRI implemented a new five-day, Monday–Friday schedule; Prelich requested accommodation due to high-risk pregnancy.
MRI informed Prelich that the schedule changes were based on external consultant recommendations and advised compliance or resignation.
Prelich disclosed a high-risk pregnancy with quadruplets and sought information on FMLA, disability, and benefits, but received none.
MRI terminated Prelich as part of a claimed reduction in force; severance and a release were offered in exchange for a waiver of claims.
Prelich filed an EEOC charge in September 2008, alleging pregnancy, disability discrimination, and retaliation; suit followed in December 2010.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Counts I–IV are time-barred	Equitable tolling applies due to defendant's misrepresentations delaying notice.	Charge filed within state deferral period still untimely.	Counts I–IV timely due to equitable tolling through 12/12/2007.
Whether equitable tolling/estoppel applies to toll the limitations period	Defendant misled about termination grounds, delaying filing.	No concealment or delay; tolling not warranted.	Equitable tolling applied; equitable estoppel not needed for ruling on Counts I–IV.
Whether Count V (Release-based retaliation) is viable	Release was facially retaliatory for filing discrimination claims.	Offer of a severance/Release is not retaliation absent adverse action.	Count V dismissed with prejudice.
Whether Count VI (FMLA retaliation) survives	FMLA retaliation claims were asserted.	FMLA claim withdrawn/dismissed.	Count VI dismissed without prejudice.

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (pleading must show plausible claim, not mere speculation)
Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (plausibility pleading standard governs Rule 12(b)(6))
Delaware State Coll. v. Ricks, 449 U.S. 250 (U.S. 1981) (filing period starts when employee learns of discriminatory decision)
Zipes v. Trans World Airlines, Inc., 455 U.S. 385 (U.S. 1982) (claim-processing rules subject to waiver, estoppel, equitable tolling)
Price v. Litton Bus. Sys., Inc., 694 F.2d 963 (4th Cir. 1982) (equitable tolling considerations in deferral states)
Felty v. Graves-Humphreys Co., 785 F.2d 517 (4th Cir. 1986) (equitable estoppel and coercive conduct considerations in tolling)
Felty v. Graves-Humphreys Co., 818 F.2d 1126 (4th Cir. 1987) (reaffirmed estoppel analysis on delay caused by employer coercion)
Rhodes v. Guiberson Oil Tools Division, 927 F.2d 876 (5th Cir. 1991) (misleading termination rationale tolls filing period)
Sturniolo v. Sheaffer, Eaton, Inc., 15 F.3d 1023 (11th Cir. 1994) (mere suspicion without pretext evidence insufficient to toll)
Jones v. Dillard's, Inc., 331 F.3d 1259 (11th Cir. 2003) (equitable tolling based on delayed discovery of pretext)