LANE v. FEA INDUSTRIES, INC.

CourtDistrict Court, E.D. Pennsylvania
DecidedOctober 21, 2022
Docket2:20-cv-06033
StatusUnknown

This text of LANE v. FEA INDUSTRIES, INC. (LANE v. FEA INDUSTRIES, INC.) 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
LANE v. FEA INDUSTRIES, INC., (E.D. Pa. 2022).

Opinion

FORI NT HTEH EE AUSNTIETREND DSTISATTREISC DTI OSTFR PIECNTN CSOYULVRAT NIA

ANTWON LANE : Plaintiff, : CIVIL ACTION : v. : NO. 20-6033 : FEA INDUSTRIES, INC. : Defendant. :

MEMORANDUM Younge, J. October 21, 2022 I. INTRODUCTION Currently before this Court is Defendant FEA Industries, Inc’s (“FEA”) Motion for Summary Judgment (ECF No. 16). The Court finds this motion appropriate for resolution without oral argument. Fed. R. Civ. P. 78; L.R. 7.1(f). For the reasons set forth in this Memorandum, Defendant FEA’s Motion for Summary Judgment (ECF No. 16) will be granted. II. FACTUAL BACKGROUND Plaintiff Antwon Lane, an African-American male, has filed a civil action against his former employer, Defendant FEA Industries, Inc., a manufacturing company, for alleged discrimination and retaliation based on race. (First Amended Complaint (hereinafter, “FAC”) ¶¶ 1, 9, 12, 32-38, ECF No. 22.) Though hired in February 2020 and then furloughed in late March 2020 due to the ensuing COVID-19 pandemic, Plaintiff would later be reinstated in early April 2020. (FAC, ¶¶ 13, 16-17, ECF No. 22.) Upon his return, Plaintiff alleges that he now had to work daily with Defendant’s President and Owner, William Heffner, III (hereinafter, “Heffner”)—who had subjected Plaintiff “to discriminatory and disparate treatment because of his race.” (FAC, ¶¶ 19-20, ECF No. 22.) More specifically, Plaintiff suggests that Heffner had been “abrasive towards Plaintiff, shook his head at Plaintiff, talked down to him, and had a look of disgust when around Plaintiff.” (FAC, ¶ 21, ECF No. 22.) Another point of contention arose regarding Defendant’s cell phone policy—whereby Heffner told Plaintiff that he could not have his phone in the workplace, while Plaintiff notes that he had been told that he could use his cell phone to listen to music while working. (FAC, ¶¶ 23-24, ECF No. 22.) Bothered by this encounter and the other perceived instances of differential treatment, Plaintiff, the very next day, asked to speak with Heffner and stated to Heffner, “I feel like you are racially discriminatory towards me.” (FAC, ¶ 27, ECF No. 22.) After Heffner allegedly yelled at Plaintiff and informed him that he was not racist, Plaintiff had been instructed to go to the break

room and to wait for HR. (FAC, ¶¶ 28-29, ECF No. 22.) Shortly thereafter, Defendant’s Human Resources Manager, Susan Younge, arrived in the break room and, after Plaintiff had expressed his concerns to her, Plaintiff notes that he had been informed that he was being terminated. (FAC, ¶ 30, ECF No. 22.) Believing that he was terminated because of his race and/or for raising concerns around racial discrimination, Plaintiff is suing Defendant for discrimination and retaliation under Title VII of the Civil Rights Act of 1964 (“Title VII”), Section 1981 of the Civil Rights Act of 1866 (“Section 1981”), and the Pennsylvania Human Relations Act (“PHRA”). (FAC, ¶¶ 31-38, ECF No. 22.) In response, Defendant has filed a motion for summary judgment—wherein Defendant notes that Plaintiff’s termination had been the result of excessive tardiness, violations

of Defendant’s cell phone policy, and insubordination—all of which had occurred during Plaintiff’s probationary period—and had nothing to do with Plaintiff’s race. (Def. Mem. of Law in Support of Mot. for Summ. J., pp. 2-6, ECF No. 16.) III. LEGAL STANDARD Summary judgment is appropriate if the movant shows “that there is no genuine dispute as to any material fact and that the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). Liberty Mut. Ins. Co. v. Sweeney, 689 F.3d 288, 292 (3d Cir. 2012). To defeat a motion for summary judgment, there must be a factual dispute that is both material and genuine. See Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 24-49 (1986); Dee v. Borough of Dunmore, 549 F.3d 225, 229 (3d Cir. 2008). A material fact is one that “might affect the outcome of the suit under the governing law[.]” Anderson, 477 U.S. at 248. A dispute over a material fact is “genuine” if, based on the evidence, “a reasonable jury could return a verdict for the nonmoving party.” Id. The movant bears the initial burden of demonstrating the absence of a genuine dispute of a material fact. Goldenstein v. Repossessors Inc., 815 F.3d 142, 146 (3d Cir. 2016). When the

movant is the defendant, they have the burden of demonstrating that the plaintiff “has failed to establish one or more essential elements of her case.” Burton v. Teleflex Inc., 707 F.3d 417, 425 (3d Cir. 2013). If the movant sustains their initial burden, “the burden shifts to the nonmoving party to go beyond the pleadings and come forward with specific facts showing that there is a genuine issue for trial.” Santini v. Fuentes, 795 F.3d 410, 416 (3d Cir. 2015) (internal quotation marks omitted) (quoting Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587 (1986)). At the summary judgment stage, the court’s role is not to weigh the evidence and determine the truth of the matter, but rather to determine whether there is a genuine issue for trial. See

Anderson, 477 U.S. at 249; Jiminez v. All Am. Rathskeller, Inc., 503 F.3d 247, 253 (3d Cir. 2007). In doing so, the court must construe the facts and inferences in the light most favorable to the non- moving party. See Horsehead Indus., Inc. v. Paramount Commc’ns, Inc., 258 F.3d 132, 140 (3d Cir. 2001). Nonetheless, the court must be mindful that “[t]he mere existence of a scintilla of evidence in support of the plaintiff’s position will be insufficient; there must be evidence on which the jury could reasonably find for the plaintiff.” Anderson, 477 U.S. at 252. IV. DISCUSSION As an initial matter, it is worth noting that Plaintiff’s claims across Title VII, Section 1981, and the PHRA can be consolidated for purposes of this analysis. See Harley v. McCoach, 928 F. Supp. 533, 538 (E.D. Pa. 1996) (“[Plaintiff’s] Title VII, PHRA, and § 1981 claims all fall under the same analytical framework, and will therefore be examined together.”) Thus, this Court will review Plaintiff’s consolidated disparate treatment and retaliation claims in turn. a. Disparate Treatment As the Third Circuit instructs, “[a] disparate treatment violation is made out when an

individual of a protected group is shown to have been singled out and treated less favorably than others similarly situated on the basis of an impermissible criterion under Title VII.” E.E.O.C. v. Metal Serv. Co., 892 F.2d 341, 347 (3d Cir. 1990). Under a disparate treatment theory, “proof of the employer's discriminatory motive is critical.” Id. Further, there are two ways to show discriminatory intent: either through (1) direct evidence; or (2) indirect and circumstantial evidence. Id. In this case, Plaintiff has not offered direct evidence of discrimination that “is so revealing of discriminatory animus that it is not necessary to rely on any presumption from the prima facie case [as is necessary in a pretext action] to shift the burden of production.” Starceski v. Westinghouse Elec. Corp., 54 F.3d 1089, 1096 (3d Cir.

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LANE v. FEA INDUSTRIES, INC., Counsel Stack Legal Research, https://law.counselstack.com/opinion/lane-v-fea-industries-inc-paed-2022.