Runion v. Equipment Transport, LLC, 1:15-cv-02159

Background

Runion was hired by Equipment Transport in May 2014 as a laborer on a six-person crew; he signed worker‑compensation acknowledgement forms.
On Sept. 30, 2014, while clearing a Newaltas machine line, Runion ingested byproduct, vomited, and sought emergency treatment; doctor cleared him with follow‑up and toxicology recommendations.
Runion testified he told his supervisor(s) and hospital staff he would "put it through workmen's comp"; he did not file a workers' compensation claim with the Bureau and produced no documentary proof of filing.
Within two weeks Equipment Transport reduced his hours and assigned him to tank‑cleaning; it terminated him on Oct. 15, 2014, citing PPE violations, property damage, terroristic threats, and prior disciplinary incidents.
Runion sued for retaliatory discharge under Pennsylvania public‑policy doctrine alleging termination for exercising workers' compensation rights; defendant moved for summary judgment.
The court found disputed facts as to adverse action and causation were not contested, but held Runion failed to produce evidence that he engaged in protected activity (i.e., notifying employer of an intent to file or actually filing a workers' compensation claim).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Runion engaged in protected activity under PA public‑policy (workers' comp)	Runion says he reported the injury and told supervisors/hospital staff he intended to file a workers' comp claim	Equipment Transport says Runion never filed a claim and did not notify the employer of any intent to file; plaintiff's testimony is uncorroborated	Held: No genuine dispute—Runion failed to produce evidence employer had notice of intent to file or that he filed; therefore no protected activity proven
Applicability of federal Title VII/McDonnell Douglas framework to PA retaliatory‑discharge claims	Runion relied on state public‑policy protection; used federal retaliation framework for proof	Equipment Transport did not contest using federal framework	Held: Court applies McDonnell Douglas burden‑shifting/retaliation framework as used by Third Circuit district courts
Adequacy of Runion's self‑serving deposition testimony at summary judgment	Runion contends his deposition suffices to create a fact issue about notice/intention	Equipment Transport contends testimony is conclusory and contradicted by other record evidence	Held: Self‑serving testimony insufficient when contradicted by other evidence; summary judgment granted
Need to decide employer's proffered non‑retaliatory reasons and spoliation claim	Runion argues reasons were pretextual and seeks spoliation sanctions for missing tape	Equipment Transport offered legitimate reasons; argued spoliation irrelevant if claim fails on protected activity	Held: Court did not reach pretext or spoliation because plaintiff failed to show protected activity; summary judgment granted

Key Cases Cited

Shick v. Shirey, 716 A.2d 1231 (Pa. 1998) (recognizing narrow public‑policy exception to at‑will employment)
McLaughlin v. Gastrointestinal Specialists, Inc., 750 A.2d 283 (Pa. 2000) (public‑policy exception standards)
Geary v. U.S. Steel Corp., 319 A.2d 174 (Pa. 1974) (at‑will employment baseline)
Rothrock v. Rothrock Motor Sales, Inc., 883 A.2d 511 (Pa. 2005) (employees may not be terminated for seeking workers' compensation)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (burden‑shifting framework for retaliation claims)
Univ. of Tex. Sw. Med. Ctr. v. Nassar, 133 S. Ct. 2517 (U.S. 2013) (but‑for causation standard in retaliation claims)
LeBoon v. Lancaster Jewish Cmty. Ctr. Ass'n, 503 F.3d 217 (3d Cir. 2007) (definition of adverse employment action)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S. 1986) (summary judgment standard)