Brenton v. F.M. Kirby Center for the Performing Arts

CourtDistrict Court, M.D. Pennsylvania
DecidedFebruary 26, 2020
Docket3:17-cv-00089
StatusUnknown

This text of Brenton v. F.M. Kirby Center for the Performing Arts (Brenton v. F.M. Kirby Center for the Performing Arts) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brenton v. F.M. Kirby Center for the Performing Arts, (M.D. Pa. 2020).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA

JOAN P. BRENTON :

Plaintiff : CIVIL ACTION NO. 3:17-89

v. : (JUDGE MANNION)

F.M. KIRBY CENTER FOR THE : PERFORMING ARTS : Defendant :

MEMORANDUM Presently before the court is the plaintiff Joan P. Brenton’s (“Brenton”) motion for reconsideration, (Doc. 47), of this court’s January 30, 2019 memorandum and order, (Doc. 44; Doc. 45), which granted summary judgment in favor of the defendant F.M. Kirby Center for the Performing Arts (“Kirby”). Based on the following, Brenton’s motion for reconsideration, (Doc. 47), will be GRANTED; the Clerk of Court will be directed to REOPEN THE CASE; and Count I of the amended complaint, (Doc. 19), will be REINSTATED.

I. BACKGROUND Since the court set forth the factual background of this case in its January 30, 2019 memorandum, it need not repeat it here. Pertinent here, on June 29, 2017, Brenton filed a two-count amended complaint, alleging violations of the Employment Retirement Income and Security Act (“ERISA”).

(Doc. 19). On November 28, 2017, Kirby filed a motion for summary judgment. (Doc. 29). On January 30, 2019, this court granted summary judgment in favor of Kirby on both counts. (Doc. 45). On February 26, 2019, Brenton filed the

present motion for reconsideration, (Doc. 47), and a brief in support, (Doc. 48). On April 11, 2019, Kirby filed a brief in opposition, (Doc. 51). The matter is now ripe for this court’s review.

II. LEGAL STANDARD “The purpose of a motion for reconsideration is to correct manifest errors

of law or fact or to present newly discovered evidence.” Harsco v. Zlotnicki, 779 F.2d 906, 909 (3d Cir. 1985). “Accordingly, a judgment may be altered or amended if the party seeking reconsideration shows at least one of the following grounds: (1) an intervening change in the controlling law; (2) the

availability of new evidence that was not available when the court granted the motion for summary judgment; or (3) the need to correct a clear error of law or fact or to prevent manifest injustice.” Howard Hess Dental Labs. Inc. v.

Dentsply Intern., Inc., 602 F.3d 237, 251 (3d Cir. 2010) (internal quotation marks omitted); see also Chesapeake Appalachia, LLC v. Scott Petroleum, LLC, 73 F.Supp.3d 488, 491 (M.D.Pa. 2014) (Generally, reconsideration motions should be granted sparingly.). “The standard for granting a motion for reconsideration is a stringent one . . . . [A] mere disagreement with the court

does not translate into a clear error of law.” Chesapeake Appalachia, 73 F.Supp.3d at 491 (quoting Mpala v. Smith, No. 3:CV-06-841, 2007 WL 136750, at *2 (M.D.Pa. Jan. 16, 2007), aff’d, 241 Fed.App’x 3 (3d Cir. 2007)).

III. DISCUSSION The plain language of §510 of ERISA provides “a cause of action for employees who have been discharged ‘for exercising any right’ to which employees are entitled to under an ERISA-protected benefit plan.” Kowalski v.

L & F Products, 82 F.3d 1283, 1287 (3d Cir. 1996). However, “Section 510 also goes further, protecting employees from interference with the attainment of any right to which [the employees] may become entitled.” Id. (internal quotation marks omitted). In interpreting §510, the Third Circuit has clarified

that “there is [ ] no limiting language in §510 that suggest that only future benefits are protected.” Id. at 1287. This means that there are two distinct causes of action under §510 of ERISA: (1) retaliatory discharge; and (2)

interference. See Kowalski, 82 F.3d at 1287. Each of these causes of action has a unique standard for a plaintiff to establish a prima facie case. In its January 30, 2019 memorandum, the court interpreted Brenton’s Count I §501 claim as a claim for interference with her attainment of ERISA benefits. In her motion for reconsideration, Brenton contends that her §501 claim was, in fact, one for retaliatory discharge for exercising her rights under

ERISA. Thus, in analyzing her claim, Brenton argues that the court incorrectly required her to show proof of specific intent to interfere with the attainment of a right to which she may become entitled in the future. Instead, Brenton

contends the court should have applied the ERISA retaliation standard set forth in Smith v. W. Manheim Twp., No. 1:11-CV-778, 2011 WL 5117618 (M.D.Pa. Oct. 25, 2011). In Smith, the plaintiff brought both an ERISA interference claim and an

ERISA retaliatory discharge claim. With regard to the ERISA interference claim, the court applied the following standard: A plaintiff can establish a prima facie claim of ERISA interference by demonstrating that: (1) prohibited employer conduct (2) taken for the purpose of interfering (3) with the attainment of any right to which the employee may become entitled. To demonstrate that an employer took action for the purposes of interfering with an ERISA right, a plaintiff must show the employer had specific intent to violate ERISA.

Id. at *2 (internal quotation marks and citations omitted).

In contrast, with regard to the ERISA retaliation claim, the court applied the following standard: A plaintiff establishes a prima facie [case] of retaliatory discharge pursuant to §510 of ERISA by demonstrating that: (1) he or she participated in a statutorily protected activity; (2) he or she was subject to an adverse employment action; and (3) there is a causal connection between the participation and the adverse action. The causal connection can be demonstrated through proof of either (1) an unusually suggestive temporal proximity between the protected activity and the allegedly retaliatory action, or (2) a pattern or antagonism coupled with timing to establish a causal link.

Id. at *3 (internal quotations marks and citations omitted).

Upon review of the second amended complaint, the court agrees that Brenton’s Count I §510 claim was one for retaliatory discharge, and not for interference, as this court originally interpreted it. Therefore, the court will re- analyze this claim in the context of Kirby’s motion for summary judgment, (Doc. 29), under the standard for retaliatory discharge set forth in Smith. As stated above, in a case for retaliatory discharge under §510 of ERISA, a plaintiff establishes a prima facie case by demonstrating that (1) he or she participated in a statutorily protected activity; (2) he or she was subject to an adverse employment action; and (3) there is a causal connection between the participation and the adverse action. Bowen v. Nationwide Mut. Ins. Co., No. 1:19-cv-17, 2019 WL 4412805, *3 (M.D.Pa. Sept. 16, 2019) (citing Smith, 2011 WL 5117618, *4). “The causal connection can be demonstrated through proof of either (1) an unusually suggestive temporal proximity between the protected activity and the allegedly retaliatory action, or (2) a pattern of antagonism coupled with timing to establish a causal link.” Id. (internal quotations marks omitted). In a claim for retaliatory discharge, there

is no requirement that a plaintiff show specific intent to violate §510. Rather, all that is required is a casual connection. Id. In reviewing the amended complaint, it is apparent that Brenton has

established a prima facie case of retaliatory discharge under §510. She participated in a statutorily protected activity when she requested a detailed accounting of her 403(b) plan and when she participated in the investigation into improper deposits into her 403(b) account. Brenton was clearly subject to

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Related

Harsco Corp. v. Lucjan Zlotnicki
779 F.2d 906 (Third Circuit, 1986)
Teresa Kowalski v. L & F Products
82 F.3d 1283 (Third Circuit, 1996)
Chesapeake Appalachia, L.L.C. v. Scout Petroleum, LLC
73 F. Supp. 3d 488 (M.D. Pennsylvania, 2014)

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