BRADY v. THE MIDDLE EAST FORUM

CourtDistrict Court, E.D. Pennsylvania
DecidedOctober 28, 2021
Docket2:21-cv-02252
StatusUnknown

This text of BRADY v. THE MIDDLE EAST FORUM (BRADY v. THE MIDDLE EAST FORUM) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
BRADY v. THE MIDDLE EAST FORUM, (E.D. Pa. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

CAITRIONA BRADY : CIVIL ACTION : v. : NO. 21-2252 : THE MIDDLE EAST FORUM, : GREG ROMAN, and DANIEL PIPES :

MEMORANDUM KEARNEY J. October 28, 2021 Caitriona Brady and her lawyer return with a fourth complaint against her former employer alleging discriminatory and retaliatory conduct from three or four years ago. She agreed to settle her discrimination and retaliation claims in early July 2020. We dismissed her claims against the employer and its agents with prejudice on July 6, 2020. She did not seek to vacate or alter our dismissal. Her former employer has allegedly not honored the settlement. She can timely sue to enforce the employer’s possible contract obligation but not in this Court unless she meets our subject matter jurisdiction. She now sues for breach of contract and again alleges discrimination and retaliation claims under Pennsylvania and Philadelphia law she could have, but did not, raise in her earlier dismissed action. Defendants move to dismiss this fourth case arguing her employment claims are barred by res judicata and we lack subject matter jurisdiction over her breach of contract claim without the employment claims. Her lawyer now argues he erred in his twenty-plus earlier instances of sworn facts and asks us to credit new facts which may allow him to argue our earlier dismissal does not bar this case. But we must hold Ms. Brady to her admissions in the complaint before us. We grant in part and deny in part Defendants’ motion to dismiss her claims. We enjoy subject matter jurisdiction from the face of the complaint but dismiss the discrimination and retaliation claims. I. Alleged Facts. Caitriona Brady began working at The Middle East Forum in May 2017 as a development associate reporting to supervisors Greg Roman and Daniel Pipes.1 She alleges discrimination based on sex, a hostile work environment, and retaliation in violation of the Pennsylvania Human Relations Act2 and the Philadelphia Fair Practices Ordinance.3 Ms. Brady alleges Defendants

subjected her to conduct violating Pennsylvania and Philadelphia discrimination laws from her hiring in May 2017 until November 2018 and again in 2019.4 She filed a charge of discrimination with the Equal Employment Opportunity Commission on June 20, 2019, dual filed with the Pennsylvania Human Relations Commission and the Philadelphia Commission on Human Relations.5 Ms. Brady’s October 29, 2019 complaint against Defendants. Ms. Brady’s filed her first complaint against The Middle East Forum, Mr. Roman, and Mr. Pipes on October 29, 2019 alleging discrimination on the basis of her sex, retaliation, and a hostile work environment leading to her constructive discharge in November 2018 in violation of Title

VII,6 the PHRA, and the PFPO.7 Ms. Brady then swore she filed a charge of discrimination with the EEOC on June 20, 2019.8 She alleged the EEOC issued her a right-to-sue letter on July 31, 2019.9 She conceded her claims under the PHRA and PFPO asserted on October 29, 2019 were not ripe because one year had not passed from the filing of her June 20, 2019 EEOC charge dual filed with the PHRC.10 Director Roman and President Pipes moved to dismiss her complaint in Brady I arguing her PHRA and PFPO claims were not yet ripe.11 We dismissed Director Roman, President Pipes, and Mr. Bennett without prejudice.12 Ms. Brady did not amend her complaint to sue the individuals after her PHRA and PFPO claims became ripe on June 20, 2020. Ms. Brady amended her complaint in Brady I on April 9, 2020 asserting disparate treatment, hostile work environment, and retaliation claims in violation of Title VII against The Middle East Forum only.13 On July 6, 2020, we dismissed Ms. Brady’s claims with prejudice after the parties advised us of their agreement to resolve the matter.14 The operative complaint at the

time of our July 6, 2020 order alleged violations of Title VII against The Middle East Forum only. Ms. Brady’s PHRA and PFPO claims became ripe on June 20, 2020 – after she filed her April 9, 2020 second amended complaint – and before our July 6, 2020 Order dismissing her complaint with prejudice, but she did not amend her complaint to include the state statutory claims or to sue the individual defendants. She did not ask us to vacate or alter the dismissal. The parties’ settlement agreement. The parties entered a settlement agreement for an undisclosed amount in July 2020. The Middle East Forum and Mr. Roman have not honored the agreement.15 She concedes the settlement payment does not exceed $75,000. II. Analysis

The Middle East Forum, Director Pipes, and President Roman move to dismiss.16 They argue (1) the state law statutory claims under the PHRA and PFPO claims are barred by claim preclusion or res judicata; and, (2) we lack jurisdiction over the breach of contract claim because it does not exceed the $75,000 jurisdictional limit.17 Ms. Brady responds res judicata does not apply because she could not have brought her PHRA and PFPO claims at the time we dismissed Brady I on July 6, 2020.18 But she swore to us in this case weeks ago of filing her first administrative claim on June 20, 2019.19 For the first time in this or the three earlier litigations against The Middle East Forum and its officers, Ms. Brady’s lawyer now argues–contrary to her sworn statements—he did not file an EEOC charge until July 18, 2019 and her state statutory claims would not have been ripe until July 18, 2020, twelve days after we dismissed Brady I with prejudice.20 Despite her multiple pleadings of a June 20, 2019 EEOC charge dual filed with the PHRC and the Philadelphia Commission on Human Relations, Ms. Brady astonishingly argues Defendants incorrectly identify June 20, 2019 as the

administrative charge date. She steps into the brazen and unsworn world of making claims in briefs contrary to her several sworn statements. She places her finances and her counsel’s license at risk. But the bottom line today is Ms. Brady cannot amend her complaint through her lawyer’s undocumented response to Defendants’ motion to dismiss. We grant Defendants’ motion to dismiss Ms. Brady’s Pennsylvania and Philadelphia discrimination and retaliation claims as barred by res judicata. We deny Defendants’ motion we lack subject matter jurisdiction. A. We enjoy subject matter jurisdiction considering all claims.

Ms. Brady invokes our jurisdiction based on diversity under 28 U.S.C. § 1332(a)(1).21 She alleges she is a citizen of New Jersey; The Middle East Forum is a Pennsylvania corporation with its principal place of business in Philadelphia; and Director Pipes and President Roman are citizens of Pennsylvania.22 She alleges an amount in controversy in excess of the $75,000 jurisdictional threshold based on damages available under the PHRA and PFPO and her contract claim. Defendants argue we lack jurisdiction over Ms. Brady’s contract claim and we must dismiss it under Rule 12(b)(1). They argue “[u]pon dismissal of the PHRA and PFPO claims due to claim preclusion, the only remaining claim … is for an alleged breach of contract.”23 They argue with the PHRA and PFPO claims dismissed, Ms. Brady’s only remaining claim – contract claim – does not exceed $75,000. Defendants put the proverbial cart before the horse. When faced with a motion to dismiss under Rule 12(b)(1) and (b)(6), we consider the jurisdictional ground first because if we lack jurisdiction to hear the case, we lack jurisdiction to rule on the merits of the case.24 We determine whether diversity jurisdiction exists “by examining ‘the facts as they exist when the complaint is filed.’”25 Our “temporal focus … is on the time that the complaint is filed.”26 “Subsequent events cannot reduce the amount in controversy so as to

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Bluebook (online)
BRADY v. THE MIDDLE EAST FORUM, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brady-v-the-middle-east-forum-paed-2021.