J. DiGregorio v. Bristol Twp. Police Benevolent Assoc. & Twp. of Bristol

CourtCommonwealth Court of Pennsylvania
DecidedJanuary 8, 2025
Docket232 C.D. 2023
StatusUnpublished

This text of J. DiGregorio v. Bristol Twp. Police Benevolent Assoc. & Twp. of Bristol (J. DiGregorio v. Bristol Twp. Police Benevolent Assoc. & Twp. of Bristol) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
J. DiGregorio v. Bristol Twp. Police Benevolent Assoc. & Twp. of Bristol, (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Joseph DiGregorio, : Appellant : : v. : No. 232 C.D. 2023 : Argued: December 9, 2024 Bristol Township Police Benevolent : Association and Township of Bristol :

BEFORE: HONORABLE PATRICIA A. McCULLOUGH, Judge HONORABLE MICHAEL H. WOJCIK, Judge (P.) HONORABLE STACY WALLACE, Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY JUDGE WALLACE FILED: January 8, 2025

Joseph DiGregorio (DiGregorio) appeals the orders of the Court of Common Pleas of Bucks County (trial court), dated March 8, 2022, granting partial summary judgment in favor of Bristol Township Police Benevolent Association (Association) and Township of Bristol (Township) on three counts in his amended complaint, and the order dated February 2, 2023, finding in favor of the Township after a bench trial on the remaining fourth count. Judgment was entered against DiGregorio on July 1, 2023. DiGregorio now challenges the trial court’s decision to grant partial summary judgment against him. After careful review, we affirm. BACKGROUND DiGregorio worked as a Township police officer from September 2007 almost continuously until the Township removed him from this position in January 2017.1 The Association is a union representing Township police officers. DiGregorio filed a complaint against the Association and Township on November 17, 2017, followed by an amended complaint on August 15, 2019. Count III of the amended complaint alleged the Association breached its duty of fair representation to DiGregorio. The remaining counts applied to the Township. Count I alleged a violation of the Family and Medical Leave Act of 1993 (FMLA),2 Count II alleged wrongful termination based on a breach of the collective bargaining agreement (Agreement) between the Association and Township, and Count IV alleged a violation of the Wage Payment and Collection Law (WPCL).3 DiGregorio averred the Township removed him from his position as a police officer based on allegations he failed to pass annual firearms testing and mishandled police matters. DiGregorio described these allegations as a mere “pretext,” alleging the Township “acted unlawfully towards [him] in an arbitrary, perfunctory, unlawful and capricious manner, in bad faith;” removed him contrary to the Agreement; and failed to pay him all the compensation he was due for unused vacation and sick time. Reproduced Record (R.R.) at 23a-29a, 32a-33a. DiGregorio averred the Association failed to protect his due process rights by filing a grievance under the Agreement or an appeal through the civil service system. Moreover, DiGregorio averred he asked

1 The Township also removed DiGregorio in June 2009, but he was reinstated after a civil service appeal and returned to work in February 2010.

2 29 U.S.C. §§ 2601-54.

3 Act of July 14, 1961, P.L. 637, as amended, 43 P.S. §§ 260.1-260.45.

2 for FMLA leave to care for an ailing family member in September 2016. He averred the Township approved his request but “intentionally and/or recklessly concealed” the approval from him, such that he was unable to take leave. Id. at 15a. On November 23, 2021, the Township filed a motion for summary judgment. The Association filed its own motion for summary judgment on December 2, 2021, followed by an amended motion for summary judgment on December 10, 2021. The Association and Township argued DiGregorio failed to exhaust his administrative remedies by failing to file a grievance under the Agreement or an appeal through the civil service system. The Association and Township argued DiGregorio never attempted to file a grievance or an appeal and could not blame this failure on them. In addition, the Township asserted it properly removed DiGregorio from his position because he failed to pass annual firearms testing and mishandled police matters. The Township denied any FMLA violation, contending DiGregorio withdrew his FMLA request three days after it was approved. The trial court entered orders, dated March 8, 2022, granting partial summary judgment in favor of the Association as to Count III of the amended complaint, based on failure to exhaust administrative remedies and legal insufficiency, and in favor of the Township as to Counts II and IV of the amended complaint, based on failure to exhaust administrative remedies. The trial court denied summary judgment as to the FMLA claim at Count I. On March 15, 2022, DiGregorio filed a petition requesting that the trial court amend its order granting partial summary judgment in favor of the Township to include language from Section 702(b) of the Judicial Code, 42 Pa.C.S. § 702(b).4 DiGregorio did not ask the trial court to amend its order

4 Section 702(b) provides:

(Footnote continued on next page…)

3 granting partial summary judgment in favor of the Association. The trial court granted DiGregorio’s petition by order dated March 22, 2022, and added the language from Section 702(b). The Township filed a motion for reconsideration, which the trial court denied. DiGregorio did not file a petition for permission to appeal under Rule 1311 of the Pennsylvania Rules of Appellate Procedure, Pa.R.A.P. 1311. Instead, on April 6, 2022, he filed a notice of appeal to the Pennsylvania Superior Court from the order granting partial summary judgment in favor of the Association as to Count III, which was docketed at 1010 EDA 2022. DiGregorio filed a second notice of appeal to this Court on April 20, 2022, from the order granting partial summary judgment in favor of the Township as to Counts II and IV, as amended, which was docketed at 400 C.D. 2022. DiGregorio later discontinued both appeals. On August 16, 2022, DiGregorio filed a petition nunc pro tunc, asking the trial court to open and supplement the record and award attorney’s fees and costs against the Association for failure to disclose evidence in discovery. DiGregorio averred he found additional documents relating to his 2009 civil service appeal in “an unmarked sealed storage container in his basement” that the Association failed to disclose. Pet. Nunc Pro Tunc, 8/16/22, ¶ 15. Based on these documents, DiGregorio alleged the Association had “intentionally refused to disclose that [its] Grievance Committee

(b) Interlocutory appeals by permission.--When a court or other government unit, in making an interlocutory order in a matter in which its final order would be within the jurisdiction of an appellate court, shall be of the opinion that such order involves a controlling question of law as to which there is substantial ground for difference of opinion and that an immediate appeal from the order may materially advance the ultimate termination of the matter, it shall so state in such order. The appellate court may thereupon, in its discretion, permit an appeal to be taken from such interlocutory order.

42 Pa.C.S. § 702(b).

4 and the Civil Service Solicitor were directly involved [in] filing his civil service appeal in 2009, concealing core material discovery on the question of exhaustion in 2017.” Id. ¶ 46. The Association and Township filed responses opposing the petition, after which the trial court entered a rule to show cause dated September 14, 2022. On September 16, 2022, DiGregorio filed a second petition nunc pro tunc to open and supplement the record and for an award of attorney’s fees and costs against the Township, citing the same documents relating to his 2009 civil service appeal. The Association and the Township filed additional responses. The Township filed a motion on October 26, 2022, in which it requested a protective order prohibiting further discovery and an award of attorney’s fees and costs against DiGregorio based on his allegedly vexatious and dilatory conduct.

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Bluebook (online)
J. DiGregorio v. Bristol Twp. Police Benevolent Assoc. & Twp. of Bristol, Counsel Stack Legal Research, https://law.counselstack.com/opinion/j-digregorio-v-bristol-twp-police-benevolent-assoc-twp-of-bristol-pacommwct-2025.