FLEMISTER v. MERAKEY USA

CourtDistrict Court, E.D. Pennsylvania
DecidedNovember 9, 2020
Docket2:20-cv-01391
StatusUnknown

This text of FLEMISTER v. MERAKEY USA (FLEMISTER v. MERAKEY USA) 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
FLEMISTER v. MERAKEY USA, (E.D. Pa. 2020).

Opinion

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

SIAH FLEMISTER : CIVIL ACTION : v. : NO. 20-1391 : MERAKEY IDD PHILADELPHIA :

MEMORANDUM KEARNEY, J. November 9, 2020 Siah Flemister claims her former employer Merakey IDD Philadelphia fired her because of her Liberian national origin rather than as a disciplinary measure. The remaining issue is whether her former employer discriminated against her. The parties engaged in discovery. Merakey now moves for summary judgment arguing Ms. Flemister failed to establish a prima facie case of discrimination based on national origin, and, even if she did establish a prima facie case of national origin discrimination, she failed to demonstrate its articulated, legitimate, non- discriminatory reason for her termination is pretextual. Ms. Flemister raises conclusory challenges. We scrutinized the adduced evidence. We find no genuine issue of material fact precluding judgment for Merakey on Ms. Flemister’s claim for discrimination based on national origin. We grant Merakey’s motion for summary judgment and dismiss the case. I. Undisputed Facts1 Ms. Flemister is Liberian.2 On July 17, 2017, Merakey hired Ms. Flemister as a Day Program Support Counselor.3 Merakey is an agency providing services to individuals with intellectual and developmental disabilities, including residential services, day program services, supported employment, supported living, and family living.4 Merakey refers to the individuals it services as “consumers.”5 Merakey maintains two primary programs: the Day Program and the Residential Program.6 Ms. Flemister worked in the Day Program which provides eight hours of education and daily living support to its consumers in a classroom setting as well as field trips into the community.7 Merakey hired Ms. Flemister as a “replacement counselor” to fill-in on an as-needed basis and not assigned to a specific classroom or consumer.8 Ms. Flemister’s responsibilities included

providing day-to-day direct care and support to consumers, assisting consumers with daily life activities, daily lessons to develop life skills, and taking consumers on field trips into the community.9 Ms. Flemister’s position is covered by a collective bargaining agreement between the National Union of Hospital and Health Care Workers, District 1199C and Merakey.10 The collective bargaining agreement governed the terms and conditions of Ms. Flemister’s employment with Merakey.11 Merakey’s Standards of Professional Behavior Policy. Merakey maintains a Standards of Professional Behavior Policy (“Policy”) for its employees proscribing, among other things: “Engaging in fighting, horseplay, practical jokes or

other disorderly conduct that causes or could cause injury to others or damage to property, or that could endanger the well-being of any employee, consumer, visitor or company property is prohibited”; “Threatening, intimidating or coercing others, using abusive or offensive or demeaning language, or interfering with the performance of others, are other examples of prohibited behavior”; and “To ensure a safe environment, Merakey prohibits abuse, mistreatment or neglect of a consumer.”12 Violations of the Policy may result in “disciplinary action up to and including termination.”13 Pennsylvania regulations governing Merakey’s services. Merakey is governed by the Pennsylvania Code’s “Intellectual Disability and Autism Manual” for providers of services to the intellectually disabled or autistic.14 The Pennsylvania Department of Human Services (formerly Department of Public Welfare) issued a “Mental Retardation Bulletin” effective February 28, 2004.15 The Bulletin provides the procedure for

“incident management” designed to “ensure that when an incident occurs, the response will be adequate to protect the health, safety and rights of the individual” and to provide “clear and specific methodologies to ensure appropriate responses at the provider, county and State levels.”16 Pennsylvania requires verbal abuse be reported within twenty-four hours of an occurrence. Pennsylvania defines “verbal abuse” as “a verbalization that inflicts or may inflict emotional harm, invoke fear or humiliate, intimidate, degrade or demean an individual.”17 Merakey immediately begins an investigation conducted by its Quality and Compliance Organization of an incident reported by an employee.18 Merakey’s investigators undergo training to become certified investigators in Pennsylvania.19

National origin statements toward Ms. Flemister in 2017. Ms. Flemister alleges support counselors with whom she worked—Laverne, Tara, and Danyelle Simmons—made disparaging comments about the food she and another Liberian co- worker, non-party Clara Russell, brought to work for lunch.20 Ms. Flemister does not claim Laverne, Tara, and Danyelle Simmons are Ms. Flemister’s supervisors. Ms. Flemister brought in “ethnic food of Liberia” for lunch and other support counselors made comments such as, “This stinks? Why do you eat this food?”21 Ms. Flemister testified co- worker Laverne on at least one occasion said, “Why do you bring in this, quote, smelly African food?” and Danyelle Simmons said, “This African fish stinks. Why you keep bringing fish to heat up in here when it make the whole place stink? [sic]”22 Ms. Flemister testified “it was just their way of coming after the food. For what reason, I don’t know.”23 Her admissions appear to conflict with her allegation she believed Ms. Simmons or Laverne directed these comments to her Liberian origin.24 Ms. Flemister alleges the support counselors who commented on her food did not make similar comments to American-born employees who brought their food in for lunch.25 Ms.

Flemister provides no evidence to support this allegation. Co-workers Laverne and Tara made comments about her accent and sometimes pretended not to understand her and said, “Speak English” and “We’re not speaking African. Don’t speak African.”26 Ms. Flemister also swore Laverne said on other occasions, “These people come in here and work here is from Africa [sic]. They don’t know what to do in my space. Nobody should be sitting in my chair. Nobody should be working in my space” and “African people don’t know how to do anything right.”27 Mr. Flemister alleges she complained to a manager and Day Program director about the food comments but they did not “properly address” her complaints.28 Ms. Flemister swore after

complaining in August 2017 to Brian Hancock, supervisor of the Day Program, about Laverne’s comments he or another supervisor assigned Ms. Flemister to a different classroom away from Laverne.29 Ms. Flemister agreed after Supervisor Hancock assigned her to a room away from Laverne, she heard no more comments about the food and Africans.30 Ms. Flemister admits she never complained to Merakey’s Human Resources about comments related to food or being African and no one other than Laverne, Tara, and Danyelle Simmons ever made any negative comments about her food.31 Ms. Flemister did not work in Laverne or Tara’s classroom after late 2017 and her situation “got better” having moved away from them and into the classroom of another co-worker, Patrice, who enjoyed her African food.32 When asked about her allegation she complained in early March 2018 about Laverne’s comments, Ms. Flemister testified she “probably” made her complaints in 2017.33 She testified she may have made a complaint in March 2018 regarding either a food comment, a “speak English” comment, or a comment from Laverne telling her she could not sit in a certain seat on a field trip bus, but cannot specifically recall.34 Ms. Flemister testified the seat on

the bus comment did not refer to her being Liberian or African.35 March 14, 2018 verbal altercation between Mses. Flemister and Simmons. On March 14, 2018, Ms.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

McDonnell Douglas Corp. v. Green
411 U.S. 792 (Supreme Court, 1973)
Scott v. Harris
550 U.S. 372 (Supreme Court, 2007)
Staub v. Proctor Hospital
131 S. Ct. 1186 (Supreme Court, 2011)
Lamont v. New Jersey
637 F.3d 177 (Third Circuit, 2011)
Ron G. McCoy v. Wgn Continental Broadcasting Co.
957 F.2d 368 (Seventh Circuit, 1992)
Patricia M. Pivirotto v. Innovative Systems, Inc
191 F.3d 344 (Third Circuit, 1999)
Greene v. Virgin Islands Water & Power Authority
557 F. App'x 189 (Third Circuit, 2014)
Judy Harris v. Dow Chemical Co
586 F. App'x 843 (Third Circuit, 2014)
Curtis Wheat v. Fifth Third Bank
785 F.3d 230 (Sixth Circuit, 2015)
Catherine Willis v. Childrens Hospital of Pittsbur
808 F.3d 638 (Third Circuit, 2015)
William Peake v. Pennsylvania State Police
644 F. App'x 148 (Third Circuit, 2016)
Donald Parkell v. Carl Danberg
833 F.3d 313 (Third Circuit, 2016)
Dewitt v. Southwestern Bell Telephone Co.
845 F.3d 1299 (Tenth Circuit, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
FLEMISTER v. MERAKEY USA, Counsel Stack Legal Research, https://law.counselstack.com/opinion/flemister-v-merakey-usa-paed-2020.