Lehigh & Northampton Transportation Auth. v. Amalgamated Transit Union Local 956

CourtCommonwealth Court of Pennsylvania
DecidedApril 11, 2025
Docket49 C.D. 2024
StatusPublished

This text of Lehigh & Northampton Transportation Auth. v. Amalgamated Transit Union Local 956 (Lehigh & Northampton Transportation Auth. v. Amalgamated Transit Union Local 956) 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
Lehigh & Northampton Transportation Auth. v. Amalgamated Transit Union Local 956, (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Lehigh and Northampton : Transportation Authority, : : Appellant : : v. : No. 49 C.D. 2024 : Argued: September 9, 2024 Amalgamated Transit Union, : Local 956 :

BEFORE: HONORABLE MICHAEL H. WOJCIK, Judge HONORABLE CHRISTINE FIZZANO CANNON, Judge HONORABLE BONNIE BRIGANCE LEADBETTER, Senior Judge

OPINION BY JUDGE WOJCIK FILED: April 11, 2025

Lehigh and Northampton Transportation Authority (LANTA) appeals from an order of the Court of Common Pleas of Lehigh County (trial court), which affirmed the arbitration award issued by William W. Lowe (Arbitrator) in favor of Amalgamated Transit Union, Local 956 (Union). The Arbitrator found that LANTA did not have just cause when it terminated Eric Gurner (Grievant) for his harassment of a security guard (T.F.1). Instead, the Arbitrator expunged Grievant’s termination in favor of a 10-day suspension, while reinstating Grievant to his former job and making him whole for any lost wages, benefits, or seniority. On appeal, LANTA

1 For her privacy, the security guard will only be identified as T.F. Any mention of her name in the decisions below have been edited to reflect this concern. For consistency, any further mention of Grievant’s last name has also been edited. argues, inter alia, that the Arbitrator’s decision contravenes Pennsylvania’s public policy against sexual harassment. Upon careful review, we are constrained to affirm.

I. Background Based on the facts as determined by the Arbitrator, the trial court summarized the background as follows:

LANTA operates a transit center in Allentown known as the “Allentown Transportation Center.”

T.F. worked as a security guard at the Allentown Transportation Center. Prior to working as a security guard, T.F. suffered a knee injury while serving in the military. T.F. had limited mobility because she was wearing a knee brace and using crutches and was restricted to working in the breakroom. Drivers, including Grievant, used the breakroom in which T.F. worked as a security guard.

LANTA maintained an Anti-Harassment Policy. Grievant received the Anti-Harassment Policy and acknowledged the contents of the policy. In addition, Grievant received anti-harassment training when he was initially hired and during his five-year employment tenure.

T.F. first encountered Grievant in May 2022. Grievant began to engage in conduct that made T.F. feel uncomfortable. On one occasion, Grievant grabbed at T.F.’s cane in a joking manner and inadvertently touched her knee in a non-sexual manner. T.F. told Grievant not [to] touch her cane or her personal belongings. In addition, Grievant began to question T.F. about her personal life.[2] Grievant told T.F. that he found it hard to believe that she was single, and asked T.F. when she was

2 The Arbitrator’s Award indicates that Grievant asked T.F. if she lived alone or with family and whether she preferred older men, while expressing his disbelief that she could be single because she was so beautiful. Arbitrator’s Award, 8/1/23, at 3. The Arbitrator’s Award is contained in the Reproduced Record at 37a-62a. 2 going to let him take her out on a date. When T.F. did not respond, Grievant asked: “What’s wrong? Do I look old enough to be your father?” T.F. did not understand why Grievant, a significantly older man, would continue to ask her out when she continued to say no to his entreaties.

During the same week that Grievant asked T.F. out on a date, Grievant, in the presence of T.F.’s supervisor . . . asked T.F. if he could massage her knee, and when she declined, offered to pay for a massage at another location. [T.F.’s Supervisor] later spoke to Grievant and told him that his behavior was creepy and weird.

One of T.F.’s co-workers . . . spoke to Grievant about his behavior to T.F. Grievant told [T.F’s co-worker] that T.F. was being a “racist” and referred to her as a “bitch.”

T.F. began to go into the bathroom to avoid dealing with Grievant[] and would ask a co-worker to text her when Grievant had left. Grievant’s presence made T.F. uncomfortable and interfered with her ability to perform her job.

On July 25, 2022, Grievant was driving a bus on which T.F. was a passenger. Grievant drove the bus fast and aggressively. Grievant drove over a curb and made multiple sharp turns. When T.F. yelled at Grievant to stop the bus so an elderly woman could exit the bus, Grievant called T.F. a “loud mouth.”

Grievant was aware of LANTA’s policy prohibiting harassment in the workplace. Grievant was not aware that T.F. found his statements and behavior unwelcome at the time the behavior was occurring. However, Grievant would have known that T.F. was uncomfortable . . . because T.F. would disappear into the bathroom whenever Grievant entered the break room.

3 Trial Court’s Op., 1/12/24, at 2-3.3 The Arbitrator also observed that in the weeks preceding the July 25, 2022 incident, Grievant’s behavior became increasingly aggressive, and “[a]t about the same time, [Grievant] was asked to give his preference for his bus route assignment and he picked the route T.F. used to travel back and forth from her residence to the job site.”4 Arbitrator’s Award at 4. Similarly, Grievant questioned T.F.’s co-worker concerning her ability to do her job and expressed his desire for T.F. to be fired. Id. at 5. Eventually, having been encouraged by her supervisor and co-worker, T.F. filed a complaint against Grievant. Arbitrator’s Award at 4-5. LANTA conducted a hearing on August 3, 2022, and reviewed the evidence before it. Arbitrator’s Award at 6. In part, this included video footage of the July 25, 2022 incident, wherein Grievant called T.F. a “fucking whore” after she had exited the bus.5 Id. For his part, Grievant denied ever asking to give T.F. a massage and claimed that it was T.F. who was actually harassing him. Id. LANTA provided Grievant additional time to produce evidence of his defense and his own harassment claim. Id. By letter on August 17, 2022, LANTA informed Grievant that based on the hearing, its own investigation, and Grievant’s own statement, he was being

3 The Trial Court’s opinion is contained in the Reproduced Record at 636a-50a.

4 The Arbitrator did not make much of this fact: “The bus route picking process occurs periodically, and in this case occurred in early June not long after he met T.F. and before the mid- June timeframe when T.F. testified that she became uncomfortable with Grievant. Additionally, the bus route picking was never mentioned in T.F.’s complaint. Thus, I do not find it indicative of, or preparatory to, the harassment of T.F.” Arbitrator’s Award at 25.

5 The Arbitrator found that this act of “venting” did not constitute harassment because Grievant was alone on the bus. Arbitrator’s Award at 25. 4 discharged for harassment. Arbitrator’s Award at 7-8. Following numerous internal appeals, LANTA upheld its termination. Id. After referral to the American Arbitration Association, the Arbitrator held a hearing on April 25, 2023. The Arbitrator characterized the issue before him as: “Did [LANTA] have just cause for the discharge of bus driver, [Grievant]? If not, what shall the remedy be?” Arbitrator’s Award at 9. The Arbitrator reviewed the pertinent provisions of the Collective Bargaining Agreement (CBA)6 and LANTA’s Anti-Harassment Policy.7 The Anti- Harassment Policy defined harassment as consisting of

unwelcome conduct, whether verbal, physical, or visual, that is based upon a person’s status such as sex, color, race ancestor, religion, national origin, age, medical condition, disability, marital status, veteran status, or citizenship status.

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