BURNS v. CITY OF PHILADELPHIA

CourtDistrict Court, E.D. Pennsylvania
DecidedJuly 9, 2025
Docket2:24-cv-01822
StatusUnknown

This text of BURNS v. CITY OF PHILADELPHIA (BURNS v. CITY OF PHILADELPHIA) 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
BURNS v. CITY OF PHILADELPHIA, (E.D. Pa. 2025).

Opinion

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

JOHN BURNS,

, Case No. 2:24-cv-01822-JDW

v.

CITY OF PHILADELPHIA,

MEMORANDUM What’s legal isn’t always the same as what’s fair. An employer can treat an employee in ways that many people would consider unfair as long as the employer doesn’t violate antidiscrimination laws. In this case, the City of Philadelphia terminated John Burns after he took an 18-month leave of absence without proper authorization. If that were the whole story, this would be an easy case. But accepting Mr. Burns’s version of events as true, some of his superiors told him it was “fine” that he remained out on an extended, unpaid leave. Understandably, that created some confusion when he tried to return to work. While Mr. Burns has reason to feel misled, he does not have evidence to show that the City’s reason for refusing to return him to restricted duty after his unapproved leave, or for terminating him, was a pretext to hide discrimination or retaliation. The City is entitled to summary judgment on each of Mr. Burns’s claims. I. BACKGROUND A. Factual History

1. Mr. Burns’s restricted duty Mr. Burns joined the Philadelphia Police Department in September 2007. The Department maintains directives designed to serve as a standard of conduct for all

personnel. Among other things, the directives include the Department’s rules, policies, and procedures relating to reporting on-duty injuries, use of leave time, and employee timekeeping. They carry the same weight as an order from the Police Commissioner. Every employee receives a copy of the directives at the start of his employment, and the

directives are available to all employees electronically. During his employment, Mr. Burns was aware of the Department’s directives, had access to them, and knew that all police officers must review and understand them. Pennsylvania law governs how the Department deals with an officer when the

officer is injured on the job. For non-work-related injuries or conditions, the Department has developed a practice of providing police officers who are temporarily disabled with “restricted duty” assignments. Pursuant to this practice, the Department attempts to find

light-duty or modified-duty work suitable to the employee’s physical capabilities instead of placing these employees in an unpaid, non-work status. An officer assigned to restricted duty must report to a particular police district or unit. While an officer is assigned to restricted duty, the commanding officer of the assigned police district or unit, who might differ from his permanent district or unit, serves as his commanding officer. Officers must request restricted duty, and only the Police Commissioner or the

Department’s Safety Office may approve restricted duty assignments. Absent approval from the Police Commissioner, restricted duty assignments are not to exceed six months. Over the course of Mr. Burns’s employment, the Department approved him for

restricted duty at various times due to non-work-related injuries or conditions. Mr. Burns worked on restricted duty status in 2008, 2013, 2015, and 2016-2017. In January 2021, Mr. Burns requested restricted duty due to a back injury. At the time of his request, Mr. Burns’s permanent assignment was with the 35th Police District. The Department

approved his request and detailed him to work at the Court Liaison Unit on restricted duty status for up to six months. On April 27, 2021, Mr. Burns claimed that he suffered a workplace injury in the Court Liaison Unit when a fellow police officer struck him in the back, aggravating his pre-existing injury. Three days later, Mr. Burns stopped reporting

to work at the Court Liaison Unit and started using his paid sick leave. “Shortly after” this incident, Mr. Burns went back to the 35th District (his permanent duty station) and asked if he could “continue to use [his] sick leave” for his injury. (ECF No. 19-4 at 29:3-18.)

Corporal Jennifer Bryan-Ferguson and other unidentified staff told Mr. Burns: “[J]ust keep us posted. That’s fine. We’ll keep you on sick leave.” ( at 29:8-9.) On May 11, 2021, Mr. Burns notified the Department about his injury and sought work-related benefits. On May 25, 2021, a representative from the Department’s Human Resources sent a letter to Mr. Burns, advising him that the Department was denying his request for benefits because it determined that his injury was not work-related. The letter

also advised Mr. Burns that his “absence from duty will be charged against your accrued personal leave [and that i]n the event that this leave is exhausted, it will be necessary for you to apply for a Medical Leave of Absence” until he could return to duty. (ECF No. 19-

43 at 1.) The Department’s directives instruct officers how to request an unpaid medical leave of absence and require that officers “do so in accordance with the procedures outlined” in the directive. (ECF No. 19-38 at 11.5.1.B.) The applicable directive provides

that employees requesting a leave of absence for medical reasons, whether paid or unpaid, must “prepare a memorandum in triplicate, and upon the approval of the District/Unit Commanding Officer, the memorandum, along with a doctor’s report, will be forwarded to Police Human Resources.” ( at 11.5.A, 11.5.5.A.)

Mr. Burns continued to use his accrued leave until it ran out on August 20, 2021. The City stopped paying Mr. Burns after he exhausted his paid leave. At that point, Mr. Burns did not return to work at the 35th District or the Court Liaison Unit. Nor did he

submit a memo to request an unpaid medical leave of absence. Instead, he went to the 35th District and spoke with Cpl. Bryan-Ferguson, Lieutenant Bizworade, and “other people” about what was going on. (ECF No. 19-4 at 31:1-2.) He asked them if he was still on medical sick leave, and they confirmed that he was and told him to keep them posted. At that time, Captain Michael Zimmerman was the commanding officer at the 35th District. In December 2021, Captain Myesha Massey took over as commanding

officer of the District. According to Mr. Burns, throughout 2021 and 2022, he was “constantly communicating” with management at the 35th District, including Capt. Massey. (ECF No. 19-4 at 35:18-19.) He saw his doctor “every month” and would bring his doctor’s notes to the city medical unit.1 ( at 75:23.) He also informed management

and asked if he could continue taking medical leave, and “they said it was fine. Just keep them posted.” ( at 76:1-2.) Mr. Burns contends that these conversations took place, in person, with Cpl. Bryan-Ferguson and Capt. Massey. Capt. Massey denies ever having

these conversations with Mr. Burns. In fact, she testified that she does not even know who Mr. Burns is. However, Cpl. Bryan-Ferguson testified that she would “guide [Mr. Burns] as to what the policy is, the procedures are with the Police Department as far as with the Safety Office and Personnel to assist him in the direction he needs to go as far

as what his options are for leave of absence and returning to work.” (ECF No. 19-24 at 11:17-21.) Mr. Burns was under the impression that he could continue to use “medical sick leave” until 2023. (ECF No. 19-4 at 34:11.) He remained unpaid during this time.

1 Based on the record, it appears that the official name of this unit is the Employee Medical Services Unit or EMS. 2. Mr. Burns’s attempted return to work In January 2023, Mr. Burns attempted to return to work on restricted duty status.

First, he went to the 35th District and met with Capt. Massey and Cpl. Bryan-Ferguson. He told them that his doctor said he was able to work on a restricted duty basis and that he intended to go to the city medical unit to get cleared to return to work. Capt. Massey

and Cpl.

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BURNS v. CITY OF PHILADELPHIA, Counsel Stack Legal Research, https://law.counselstack.com/opinion/burns-v-city-of-philadelphia-paed-2025.