Sandra Connelly v. Lane Construction Corp
2016 U.S. App. LEXIS 366
| 3rd Cir. | 2016Background
- Connelly, hired in 2006 as a union truck driver at Lane’s Pittsburgh facility, was the only woman among seven drivers and ranked fifth in seniority; Lane has employed no female truck drivers there since 2010.
- From 2007 onward Connelly alleges persistent gender-based harassment by male co-workers, reports to supervisors and Lane’s Ethics Line, and a 2010 unwanted physical advance by foreman George Manning (which she reported).
- Connelly was laid off in October 2010 before the end of the season despite her seniority and was not recalled for the 2011 season; Lane recalled her six male co-workers (two with less seniority).
- Connelly filed suit asserting Title VII and PHRA claims for gender-based disparate treatment, hostile work environment/sexual harassment, and retaliation; the district court dismissed all claims with prejudice (denying leave to amend), allowing only a retaliation claim to survive initially but later dismissing the amended complaint.
- On appeal, the Third Circuit reviewed whether Connelly’s amended complaint met Twombly/Iqbal pleading standards for disparate treatment and retaliation and whether the district court erred in its pleading analysis and denial of leave to amend.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether amended complaint plausibly alleged gender-based disparate treatment (failure to rehire) | Connelly alleged she was the only female driver, qualified, not rehired while six male drivers were recalled (including two less senior), and Lane deviated from past practices in 2011 — supporting an inference of gender motive or pretext | Lane argued Connelly failed to plead facts establishing that gender motivated the non-rehire and that she did not plead a prima facie case | Court held Connelly pleaded sufficient factual allegations to make disparate-treatment claim plausible; district court erred by effectively requiring a prima facie showing at pleading stage |
| Whether amended complaint plausibly alleged retaliation (failure to rehire after protected complaints) | Connelly alleged multiple reports of harassment (including the May 2010 complaint about Manning), strained relations thereafter, and non-rehire in 2011 — supporting causal inference | Lane argued lack of temporal proximity (last protected act ~May 2010, non-rehire ~April 2011) and absence of demonstrated antagonism | Court held retaliation claim was plausible: seasonal nature of employment and intervening facts permit inference of causation; temporal gap not fatal at pleading stage |
| Whether district court properly denied leave to amend | Connelly requested leave to bolster factual allegations if complaint dismissed | Lane opposed further amendment | Court did not reach denial-of-leave issue because it vacated dismissal on pleadings; remanded for further proceedings (implicitly leaving amendment question open) |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for pleadings)
- Ashcroft v. Iqbal, 556 U.S. 662 (distinguishing factual allegations from legal conclusions at pleading stage)
- Swierkiewicz v. Sorema, N.A., 534 U.S. 506 (prima facie case is an evidentiary, not pleading, requirement)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for discrimination claims)
- Price Waterhouse v. Hopkins, 490 U.S. 228 (mixed-motive discrimination framework)
- Fowler v. UPMC Shadyside, 578 F.3d 203 (Third Circuit guidance on pleading employment claims)
- Phillips v. Cty. of Allegheny, 515 F.3d 224 (Twombly does not eliminate reasonable-inference standard; discovery may reveal proof)
- Watson v. Southeastern Pa. Transp. Auth., 207 F.3d 207 (interpretation of mixed-motive amendment)
- Armbruster v. Unisys Corp., 32 F.3d 768 (effect of Price Waterhouse proof and burdens)