Jennifer McLaughlin v. WalMart

CourtCourt of Appeals for the Third Circuit
DecidedDecember 3, 2024
Docket23-3201
StatusUnpublished

This text of Jennifer McLaughlin v. WalMart (Jennifer McLaughlin v. WalMart) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jennifer McLaughlin v. WalMart, (3d Cir. 2024).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT _____________

No. 23-3201 _____________

JENNIFER A. MCLAUGHLIN, Appellant v.

WALMART ________________

On Appeal from the United States District Court for the Eastern District of Pennsylvania (D.C. Civil No. 2-22-cv-03272) District Judge: Honorable John M. Younge ______________

Submitted Pursuant to Third Circuit L.A.R. 34.1(a) September 9, 2024 ______________

Before: CHAGARES, Chief Judge, ROTH and RENDELL, Circuit Judges.

(Opinion filed: December 3, 2024) ____________

OPINION* ____________

* This disposition is not an opinion of the full Court and, pursuant to I.O.P. 5.7, does not constitute binding precedent. CHAGARES, Chief Judge.

Jennifer McLaughlin, an assistant store manager at a Pennsylvania Walmart, left

her job in 2019. She later filed a lawsuit claiming that Walmart violated the federal

Family and Medical Leave Act (“FMLA”), 29 U.S.C. § 2601 et seq., and the Americans

with Disabilities Act (“ADA”), 42 U.S.C. § 12101 et seq. The District Court granted

Walmart’s motion for summary judgment, finding that McLaughlin voluntarily left her

job, thereby suffering no adverse employment action for the purposes of her FMLA and

ADA claims, and due to her separation, could not have suffered interference with her

FMLA rights. McLaughlin appealed. For the reasons that follow, we will affirm the

District Court’s order.

I.1

Jennifer McLaughlin worked for Walmart from November 2012 until October

2019.2 She worked as a Front-End Assistant Store Manager at a Boothwyn, Pennsylvania

store from 2016 until the time of her separation. She suffered pelvic injuries in August

2018.

McLaughlin took multiple leaves of absence during her time at Walmart, including

several periods of FMLA leave due to her injury and a pregnancy. Walmart employees

1 Because we write for the parties, we recite only facts pertinent to our decision.

McLaughlin provided no fact section in her brief, instead incorporating by reference the facts she pled in her opposition to summary judgment. But McLaughlin failed to respond to Walmart’s statement of undisputed material fact in the District Court. Therefore, many of these facts come from Walmart’s statement of undisputed material facts as they are deemed admitted. See Fed. R. Civ. P. 56(e)(2); U.S. District Judge John Milton Younge, Policies and Procedures: General Matters, Civil Cases, and Criminal Cases 14, 2 like McLaughlin must request leaves of absence through a third-party leave

administrator, which makes the final decision approving or denying leave requests.

Walmart employees must also upload supporting medical documentation for the third-

party leave administrator’s review, when necessary. The third-party leave administrator

approved, denied, and asked for supporting medical documentation with respect to

McLaughlin’s various requests for FMLA and other leave made from December 2016

until the time of her separation.

McLaughlin testified that her supervisors made comments related to her injury at

work. When McLaughlin leaned on counters or stacks of boxes as she tried to take

pressure off her hip, she claimed that her supervisors remarked “you still got to get things

done” and it was “not a good look for our customers.” Appendix (“App.”) 272. She also

claimed that her supervisors refused to accommodate her disability and represented to her

https://www.paed.uscourts.gov/sites/paed/files/documents/procedures/youpol.pdf (“Without exception, all facts set forth shall be deemed admitted unless addressed by the opposing party as set forth herein.”). McLaughlin also concedes that Walmart’s statement of undisputed facts is admitted. We also draw facts from McLaughlin’s procedurally improper factual narrative opposing summary judgment. See U.S. District Judge John Milton Younge, supra, at 14 (“Judge Younge requires the parties to file separate statements of material facts (i.e., not simply a factual narration section of a brief) . . . .” (emphasis in original)). 2 McLaughlin also previously worked at Walmart from March 2009 until she was terminated in December 2010. But this appeal does not concern that period of employment.

3 that her FMLA leave requests3 were denied. McLaughlin stated that her supervisors

would often assign her additional work, as well.

McLaughlin eventually signed a job offer letter from Giant Food Stores, LLC

(“Giant”) on August 31, 2019. Over a month later, on October 8, she texted her Walmart

store manager, “I’d like to give a two week notice, but I can’t work it. It’s too much on

my health. I’ll need to stop by and give my keys. Say goodbye to everyone.” App. 210.

She began working at Giant on October 10 — only two days after texting her resignation

notice. On October 21 — twelve days into her new job — McLaughlin texted her

Walmart store manager “Was I termed for medical? Or job abandonment?” App. 383.

Her manager replied, “Health.” App. 383.

McLaughlin timely filed her discrimination claim with the Equal Employment

Opportunity Commission on August 9, 2020. She received her right-to-sue letter on May

19, 2022. She timely filed her complaint in the District Court, which later granted

Walmart’s motion for summary judgment. McLaughlin then timely appealed.

II.

The District Court had jurisdiction pursuant to 28 U.S.C. § 1331. This Court has

appellate jurisdiction pursuant to 28 U.S.C. § 1291. Our review of the District Court’s

grant of summary judgment is plenary. Physicians Healthsource, Inc. v. Cephalon, Inc.,

954 F.3d 615, 618 (3d Cir. 2020). We apply the same standard as the District Court:

summary judgment is appropriate only when “there is no genuine dispute as to any

3 It is not clear from McLaughlin’s factual narrative in opposition to summary judgment whether her supervisor told her one or two of her FMLA leave requests were denied. 4 material fact and the movant is entitled to judgment as a matter of law.” Id. (citing Fed.

R. Civ. P. 56(a)). We view all “the facts in the light most favorable to the nonmoving

party and draw all inferences in that party’s favor.” Stone v. Troy Constr., LLC, 935

F.3d 141, 147 n.6 (3d Cir. 2019) (quoting Prowel v. Wise Bus. Forms, Inc., 579 F.3d 285,

286 (3d Cir. 2009)).

III.

McLaughlin brings two types of claims: (1) retaliation claims under the FMLA

and ADA, and (2) an FMLA interference claim.4 We address these claims in turn.

A.

Retaliation claims are cognizable under the FMLA and ADA. See Canada v.

Samuel Grossi & Sons, Inc., 49 F.4th 340, 346 (3d Cir. 2022). And they are both

analyzed pursuant to the burden-shifting framework established in McDonnell Douglas

Corp. v. Green,

Related

McDonnell Douglas Corp. v. Green
411 U.S. 792 (Supreme Court, 1973)
Prowel v. Wise Business Forms, Inc.
579 F.3d 285 (Third Circuit, 2009)
Ronald Ross v. Kevin Gilhuly
755 F.3d 185 (Third Circuit, 2014)
Ramara Inc v. Westfield Insurance Co
814 F.3d 660 (Third Circuit, 2016)
Linda Stone v. Troy Construction LLC
935 F.3d 141 (Third Circuit, 2019)
Physicians Healthsource Inc v. Cephalon Inc
954 F.3d 615 (Third Circuit, 2020)
M. S. v. Susquehanna Twp Sch Dist
969 F.3d 120 (Third Circuit, 2020)
Canada v. Samuel Grossi & Sons Inc
49 F.4th 340 (Third Circuit, 2022)

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