Standen v. Gertrude Hawk Chocolates, Inc.
3:11-cv-01988
M.D. Penn.Mar 19, 2014Background
- Plaintiff Standen worked for Hawk Chocolates from 1992 as a Candy Packer, later Packaging Technician, until 2008 when she took 8 weeks of FMLA leave and resigned.
- From 2002–2008 Standen alleges she suffered sexual harassment by three male employees, creating a severe and pervasive hostile work environment.
- Standen filed a Title VII and PHRA claim, with Count I alleging hostile environment based on sex from 2002–2008.
- Plaintiff filed complaints up the chain of supervision, including a last chance complaint to CEO David Hawk on November 11, 2008.
- This motion in limine involves pretrial evidentiary rulings; the court denies the motions and allows evidence of emotional distress, including suicide attempt, and related feelings/emotions, with limits on medical opinions.
- Plaintiff does not intend to introduce medical opinions, diagnoses, or prognoses.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether suicide attempt evidence is admissible | Standen argues it is relevant to liability and damages | Hawk contends it is prejudicial and irrelevant | Admissible; probative value not substantially outweighed by prejudice |
| Whether plaintiff may offer lay testimony on emotional distress | Standen should describe emotions and distress from harassment | Plaintiff lacks medical expertise and risks prejudice | Admissible under Rule 701; no required expert medical testimony |
Key Cases Cited
- Meritor Savings Bank, FSB v. Vinson, 477 U.S. 57 (1986) (establishes elements of hostile work environment and severity standard)
- Harris v. Forklift Sys., Inc., 510 U.S. 17 (1993) (psychological harm relevance to abuse determination)
- McQueeney v. Wilmington Trust Co., 779 F.2d 916 (3d Cir. 1985) (broad scope of relevant evidence under Rule 402/401)
- Jensen v. Potter, 435 F.3d 444 (3d Cir. 2006) (elements of hostile work environment; causation and liability)
- Carter v. Hewitt, 617 F.2d 961 (3d Cir. 1980) (Rule 403 prejudicial vs. unfair prejudice)
- Bolden v. Southeastern Pennsylvania Transportation Authority, 21 F.3d 29 (3d Cir. 1994) (emotional distress damages may be proved without expert testimony)