Susan Galette v. Avenue 365 Lending Services LLC
24-1221
| 3rd Cir. | Feb 7, 2025Background
- Susan Galette worked as a funding specialist for Avenue 365 Lending Services LLC starting in 2012.
- She worked remotely due to a medical condition during the COVID-19 pandemic; Avenue 365 later ended remote work for the funding department.
- Galette requested a permanent work-from-home accommodation in 2022, but Avenue 365 denied the request due to the essential job duties requiring in-office presence.
- When Galette refused to return to in-office work, she was terminated; Avenue 365 did not hire a replacement and was instituting a hiring freeze and reductions in force.
- Galette sued for disability discrimination (ADA), failure to accommodate, and age discrimination (ADEA), as well as parallel state law claims under the PHRA.
- The District Court granted summary judgment for Defendants on all claims, leading to this appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Disability discrimination | She is disabled and could work remotely with an accommodation (printer). | Essential job functions require in-office presence; remote accommodation is not reasonable. | No prima facie case; could not perform essentials. |
| Failure to accommodate (ADA/PHRA) | Accommodation would allow her to continue job remotely. | Accommodation would impose impractical burdens; remote tasks are limited by security policies. | No valid claim; employer need not remove essentials. |
| Age discrimination (ADEA/PHRA) | Younger, remote funding specialists kept jobs; job ad posted after her termination. | Plaintiff not similarly situated; no replacement hired; job ad irrelevant due to hiring freeze. | No pretext or inference of age discrimination. |
| Pretext for nondiscriminatory reason | Employer’s justification for termination was a cover for discrimination. | Termination was due to refusal to return to office, not a protected characteristic. | No evidence of pretext; summary judgment affirmed. |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishes burden-shifting framework for proving discrimination claims)
- Turner v. Hershey Chocolate USA, 440 F.3d 604 (details factual inquiry into essential job functions for ADA claims)
- Willlis v. UPMC Children's Hosp. of Pittsburgh, 808 F.3d 638 (sets standard for prima facie age discrimination case)
- Monaco v. Am. Gen. Assurance Co., 359 F.3d 296 (addresses comparator analysis in age discrimination claims)
- Gaul v. Lucent Techs. Inc., 134 F.3d 576 (discusses reasonable accommodation under the ADA)