Yanoski v. Silgan White Cap Americas, LLC
179 F. Supp. 3d 413
| M.D. Penn. | 2016Background
- Yanoski worked as a Press Mechanic at Silgan's Hazleton plant from 1988 until termination on August 23, 2013; the plant operated under a CBA that permits termination after two years of medical leave.
- Yanoski was diagnosed with muscular dystrophy (MD) years before the 2011 work injury; he did not disclose MD widely and never previously sought accommodations for it.
- After an August 2011 shoulder/neck workplace injury, Yanoski was placed on leave, treated by several physicians, and obtained varying medical releases (some with restrictions, Drs. Falvello/Kline/Krassen; and an unrestricted release from Dr. Haber in April 2013).
- Silgan required a fitness-for-duty exam; Dr. Spangler (May 2013) could not clear Yanoski without a full functional capacity evaluation (FFCE). Silgan refused to pay for the FFCE; Yanoski offered to pay if Silgan would promise reinstatement upon passing; Silgan did not provide that assurance.
- The Union filed and later withdrew a grievance; Silgan terminated Yanoski under the CBA medical-leave termination provision after two years of leave. Yanoski sued under the ADA for disability discrimination and retaliation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Retaliation (post-grievance firing) | Yanoski says he was fired after filing a grievance opposing Silgan’s practices | Silgan argues plaintiff cannot show causation and failed to exhaust administrative remedies | Court: Granted summary judgment for Silgan (Yanoski failed to oppose the motion; retaliation claim dismissed) |
| Disability status under ADA (actual/record/regarded-as) | MD substantially limits neurological function; Silgan knew of MD and treated him as a liability | Silgan contests that MD limited major life activities and disputes basis for actions (work injury vs MD) | Court: Genuine issues of material fact exist as to actual, record, and regarded-as disability; summary judgment denied |
| Qualified and essential functions / accommodation request | Yanoski sought to return with accommodation: avoid Line 15 or get assistance on Line 15; argues this is reasonable | Silgan contends lifting on all lines (including Line 15) is an essential function and his request would render him unqualified | Court: Disputed factual issues (e.g., whether Line 15 differs and assistance is common); summary judgment denied on qualification and accommodation claims |
| Pretext for termination (application of CBA medical-leave rule) | Yanoski contends the two-year leave termination was pretextual because Silgan repeatedly referenced his "condition"/MD, demanded extra testing, refused FFCE payment, and ignored multiple physician releases | Silgan asserts it legitimately applied the CBA termination-after-two-years rule following extended medical leave | Court: Evidence could permit a jury to find Silgan’s stated reason was pretext for disability discrimination; summary judgment denied on pretext issue |
Key Cases Cited
- Wright v. Corning, 679 F.3d 101 (3d Cir.) (summary-judgment standard review)
- Anderson v. Liberty Lobby, 477 U.S. 242 (U.S. 1986) (summary judgment—reasonable jury standard)
- Celotex Corp. v. Catrett, 477 U.S. 317 (U.S. 1986) (party opposing summary judgment must show specific facts)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (burden-shifting framework for discrimination claims)
- Williams v. Philadelphia Housing Auth. Police Dep’t, 380 F.3d 751 (3d Cir.) (elements of ADA retaliation claim)
- Krouse v. American Sterilizer Co., 126 F.3d 494 (3d Cir.) (employer’s burden to articulate legitimate nondiscriminatory reason)
- Shaner v. Synthes, 204 F.3d 494 (3d Cir.) (McDonnell Douglas applies to ADA retaliation)
- Skerski v. Time Warner Cable Co., 257 F.3d 273 (3d Cir.) (prima facie ADA failure-to-accommodate claim)
- Walton v. Mental Health Ass’n, 168 F.3d 661 (3d Cir.) (accommodation burden and ineffective accommodation)
- Fuentes v. Perskie, 32 F.3d 759 (3d Cir.) (evidence required to show pretext)