Thomas Jefferson University Hospitals, Inc. v. Pennsylvania Department of Labor & Industry, 131 A.3d 567

Haubrich was discharged by Thomas Jefferson University Hospitals, Inc. (TJU) on August 9, 2013 and, one week later (August 16, 2013), through counsel, requested to inspect her TJU personnel file under the Personnel Files Act (Act).
TJU denied the request; Haubrich filed a complaint with the Department of Labor and Industry (Department) on January 20, 2014 seeking access under the Act.
Parties stipulated to the facts and agreed no evidentiary hearing was necessary; briefing and oral argument addressed whether Haubrich qualified as an "employee" under the Act.
The Department granted Haubrich access to her personnel file on November 17, 2014; TJU appealed to the Commonwealth Court.
The Court considered statutory definitions and construction, legislative-history arguments, and prior case law about whether a recently discharged person counts as an "employee."
The Court also reviewed whether the Department’s factual finding that Haubrich was discharged without advance notice was supported by substantial evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a person who requested access one week after discharge is an "employee" under the Personnel Files Act	Haubrich: recently discharged individual qualifies as a current "employee" for Act purposes and may inspect file to learn basis for termination	TJU: "employee" means only those currently employed, laid off with reemployment rights, or on leave; former employees are excluded	Court held recently discharged worker is an "employee" under the Act (construing "currently employed" to include contemporaneous or reasonably immediate post-termination requests)
Whether the Department’s finding that Haubrich had no advance notice of termination is supported by substantial evidence	Haubrich: stipulation and disciplinary form show termination and date of incident same day, supporting lack of advance notice	TJU: contested whether there was notice	Court held the finding was supported by substantial evidence based on the stipulation and disciplinary action form

Beitman v. Department of Labor and Industry, 675 A.2d 1300 (Pa. Cmwlth. 1996) (treats contemporaneous or reasonably immediate post-termination requests as within Act’s scope)
Bangor Area Educ. Ass'n v. Angle, 720 A.2d 198 (Pa. Cmwlth. 1998) (states purpose of Act to let employees review employer-held personnel files about themselves)
Pickens (Estate of Sherman) v. Underground Storage Tank Indemnification Bd., 890 A.2d 1117 (Pa. Cmwlth. 2006) (definition of "current" employment may include "most recent")
Allstate Life Ins. Co. v. Commonwealth, 992 A.2d 910 (Pa. Cmwlth. 2010) (principles of statutory construction and giving effect to all statutory provisions)
Commonwealth v. Lynn, 114 A.3d 796 (Pa. 2015) (limits use of subsequent legislative action/amendments to infer original legislature’s intent)
Stage Rd. Poultry Catchers v. Department of Labor & Industry, 34 A.3d 876 (Pa. Cmwlth. 2011) (standard for substantial‑evidence review)