Thiel, K. v. Penn. Leadership Charter School, 973 EDA 2017

Background

Plaintiffs Kathleen Thiel and Jenna Gruber were full‑time teachers at Pennsylvania Leadership Charter School (PLCS) during various periods between 2009 and 2013. They alleged PLCS failed to pay annual bonuses of up to 10% of salary.
PLCS’s employee manual described the bonus program as discretionary and conditioned on benchmarks and financial factors; the board approved some bonuses for earlier years but Plaintiffs did not receive bonuses during their tenure.
Plaintiffs sued for breach of contract and wage payment/collection claims on behalf of a putative class of salaried PLCS employees for academic years 2008‑2009 through 2011‑2012 who did not receive a 10% bonus.
Plaintiffs sought class certification under Pa.R.C.P. 1702. They alleged CEO James Hanak orally promised bonuses during interviews; they conceded many putative class members either do not recall or deny any oral promise.
The trial court denied class certification, finding lack of commonality and typicality. Plaintiffs appealed; the Superior Court reviewed for abuse of discretion and affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether common questions of law/fact exist to certify the class	Nonpayment of bonuses is a common injury; oral guarantees by Hanak are part of the class theory and are not outcome‑determinative	Many class members lack evidence of any oral promise; their claims rest on the discretionary manual language, so claims differ individually	No. Court held lack of commonality because some class members cannot rely on the same evidence (Hanak’s oral promises) as Plaintiffs
Whether Plaintiffs’ claims are typical of the class	Plaintiffs' claims arise from same course of conduct and legal theory as class members	Plaintiffs did not work in all alleged years (e.g., 2008‑2009) and cannot recover for some class‑period claims, so their interests diverge	No. Court held Plaintiffs’ inability to recover for certain years defeated typicality
Whether the court improperly relied on merits evidence in denying certification	Plaintiffs argued the trial court misapplied evidence of oral promises and should not assess its weight at certification	Defendant argued differing evidence among class members is relevant to commonality and predominance	Court declined to reweigh merits but found that evidence differences meant no common question suitable for class treatment
Whether class action would be a fair and efficient method for adjudication	Plaintiffs argued class would efficiently adjudicate uniform nonpayment claims	Defendant argued individual inquiries (reliance, causation, discrete years) predominate	Court held class action was not fair/efficient because individual issues predominated

Key Cases Cited

McGrogan v. First Commonwealth Bank, 74 A.3d 1063 (Pa. Super. 2013) (discussing appealability of class certification orders under collateral order doctrine)
Baldassari v. Suburban Cable TV Co., Inc., 808 A.2d 184 (Pa. Super. 2002) (standard of review for denial of class certification)
Samuel‑Bassett v. Kia Motors America, Inc., 34 A.3d 1 (Pa. 2011) (trial courts should not resolve merits at class certification; commonality/predominance principles)
Clark v. Pfizer Inc., 990 A.2d 17 (Pa. Super. 2010) (if individual reliance/causation cannot be proved with common evidence, commonality fails)
Eisen v. Independence Blue Cross, 839 A.2d 369 (Pa. Super. 2003) (individual origins/defenses to disputed facts defeat commonality/predominance)