Williams v. Pennsylvania Human Relations Commission
870 F.3d 294
| 3rd Cir. | 2017Background
- Cheryl Williams, an African-American woman, worked as a Human Relations Representative at the Pennsylvania Human Relations Commission (the Commission) from 1999 to her resignation in 2014.
- Williams alleges persistent discrimination and harassment by supervisors Retort (Caucasian) and Stalczynski, leading to a hostile work environment and constructive discharge.
- Alleged incidents include a five-day unpaid suspension in 2009, workstation accommodations denied in 2010, a short performance-improvement plan in 2010, being struck in 2011, a coworker overhearing a profane insult in 2012, and a 2013 reprimand for leave requests.
- She filed an EEOC charge in November 2013; after administrative processing, she filed a four-count complaint in federal court, later narrowed to Title VII against the Commission and §1983 claims against Retort and Stalczynski.
- The district court granted summary judgment: §1983 claims against Retort and Stalczynski were foreclosed by the comprehensive remedial scheme; Title VII claims against the Commission were time-barred and not supported by the record.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Title VII/ADA claims may be pursued under §1983. | Williams argues §1983 provides a route for Title VII/ADA violations. | Retort/Stalczynski contend §1983 cannot vindicate pure Title VII/ADA rights. | No; §1983 cannot support standalone Title VII/ADA claims. |
| Whether Williams's Title VII claims against the Commission survive summary judgment. | Williams asserts hostile environment and constructive discharge merits. | Defendants argue no triable issues of fact and no actionable conduct. | Affirmed summary judgment for the Commission on Title VII claims. |
Key Cases Cited
- City of Rancho Palos Verdes v. Abrams, 544 U.S. 113 (2005) (comprehensive statutory scheme forecloses §1983 actions for related rights)
- Middlesex County Sewerage Auth. v. National Sea Clammers Ass'n, 453 U.S. 1 (1981) (unusually elaborate enforcement provisions preclude §1983 actions)
- Fitzgerald v. Barnstable Sch. Comm., 555 U.S. 246 (2009) (remedial scheme comprehensiveness governs §1983 availability)
- Hil debrand v. Allegheny Cty., 757 F.3d 99 (3d Cir. 2014) (comprehensive remedial scheme precludes some §1983 claims)
- A.W. v. Jersey City Pub. Sch., 486 F.3d 791 (3d Cir. 2007) (en banc; comprehensive remedial scheme precludes certain §1983 claims)