MASTRIPOLITO v. JEFFERSON HEALTH-NEW JERSEY

District Court, D. New Jersey·Decided August 12, 2022·No. 1:19-cv-21708·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY

LAUREN MASTRIPOLITO, : CIVIL ACTION : NO. 19-21708 Plaintiff, : : v. : : JEFFERSON HEALTH-NEW JERSEY, : : Defendant. :

M E M O R A N D U M

EDUARDO C. ROBRENO, J. August 12, 2022

I. INTRODUCTION This case concerns a hostile work environment claim brought by Lauren Mastripolito (“Plaintiff”) against her former employer, Jefferson Health – New Jersey (“Defendant”). Plaintiff alleges that she was sexually assaulted by her coworker, Anthony Hailey, at Defendant’s Washington Township Dialysis Center. Plaintiff alleges that after she filed an internal complaint against Hailey with Defendant, Defendant failed to take proper remedial measures, in violation of Title VII of the Civil Rights Act of 1964 and New Jersey’s Law Against Discrimination. Before the Court is Defendant’s motion to exclude the expert report and testimony of Michael Torchia, Esq., Plaintiff’s employment expert. For the following reasons, the Court will grant the motion in part and deny it in part. Though certain portions of the report should be struck because the report improperly relies on evidence previously deemed inadmissible, the Court will not exclude Torchia’s report and testimony in their entirety. II. BACKGROUND: TORCHIA’S PRIOR REPORT

In support of her hostile work environment claim, Plaintiff retained Michael Torchia, Esq., an employment lawyer based in Pennsylvania who has testified as an expert on workplace investigations in other cases. Plaintiff offers Torchia’s report as a means to establish employer liability. “[E]mployer liability for co-worker harassment exists only if the employer failed to provide a reasonable avenue for complaint or, alternatively, if the employer knew or should have known of the harassment and failed to take prompt and appropriate remedial action.” Huston v. Procter & Gamble Paper Prod. Corp., 568 F.3d 100, 104 (3d Cir. 2009). “[T]he law does not require that investigations into sexual harassment

complaints be perfect. Rather, to determine whether the remedial action was adequate, we must consider whether the action was reasonably calculated to prevent further harassment.” Knabe v. Boury Corp., 114 F.3d 407, 412 (3d Cir. 1997) (internal citations and quotation marks omitted). However, an “investigation might be carried out in a way that prevents the discovery of serious and significant harassment by an employee such that the remedy chosen by the employer could not be held to be reasonably calculated to prevent the harassment.” Id. at 414. Defendant previously moved to exclude Torchia’s expert report and testimony. Defendant did not contest Torchia’s credentials, but instead argued that the report impermissibly

opined on the ultimate legal conclusion of whether Defendant’s actions were “reasonably calculated to prevent further harassment,” and that allowing Torchia to testify would not assist the trier of fact. Id. In considering Defendant’s motion, the Court explained that Torchia’s report “include[d] several pages that outline the relevant caselaw and legal standard” and held that those portions of the report should be excluded. Mastripolito v. Jefferson Health-New Jersey, __ F. Supp. 3d ___, 2022 WL 334169 at *2 (D.N.J. Feb. 2, 2022). The Court held that Torchia would not be permitted to offer an ultimate legal conclusion on the issues. Id. at *4. The Court additionally held that Torchia

would be permitted to generally “offer[] an opinion on the relevant industry standards for conducting a proper and appropriate investigation,” and that Torchia would be permitted to submit an updated report to that effect. Id. The Court also ruled on several other motions in limine, which were distinct from Defendants’ motion to exclude Torchia’s report. Of relevance here, the Court granted Defendant’s motion to exclude evidence of Hailey’s past workplace conduct, including evidence related to attendance issues, performance write-ups, absences, and improper methods of collecting patient vital signs because such evidence would be inadmissible under Federal Rule of Evidence 404(b). Id. at *4-*5. The Court also

held that evidence of a 2008 workplace incident report and a related corrective action notice involving a patient’s allegations of sexual misconduct against Hailey were inadmissible under Federal Rule of Evidence 403 because the incident report “is more than a decade old, is somewhat illegible, and does not clearly describe what Mr. Hailey was accused of.” Id. at *6.1 Plaintiff has since submitted a revised expert report and Defendant now moves to exclude/strike2 it. In its motion, Defendant argues that Torchia’s revised report references evidence that the Court previously held was inadmissible so

1 The Court also granted Defendant’s motion to exclude evidence of Hailey’s past criminal history as unopposed. The Court additionally considered whether an email detailing a human resources’ interview with another employee should be excluded as hearsay. Id. In the email, the human resources employee explained that Hailey made “creepy” comments to her. Id. The Court held Plaintiff could not use the contents of this email to prove the truth of the matter asserted, but held that the email could be introduced for the limited purpose of determining whether the head of Defendant’s human resources department properly considered this information in her investigation. Id. at *6-*7.

2 While Defendant frames this as a motion to strike, and while certain portions of Torchia’s report should be struck, the Court will consider this to be a motion in limine because Defendant’s arguments are premised on the Federal Rules of Evidence. Torchia’s report and testimony should be excluded in their entirety. The motion is now ripe before the Court. III. LEGAL STANDARD Motions in limine “allow the trial court to rule in advance of trial on the admissibility and relevance of certain

forecasted evidence.” United States v. Tartaglione, 228 F. Supp. 3d 402, 406 (E.D. Pa. 2017) (citing Bradley v. Pittsburgh Bd. of Educ., 913 F.2d 1064, 1069 (3d Cir. 1990)). “The trial court should exclude evidence on a motion in limine only when the evidence is clearly inadmissible on all potential grounds.” Id. (citing Leonard v. Stemtech Health Sciences, Inc., 981 F. Supp. 2d 273, 276 (D. Del. 2013)). The party seeking to exclude evidence “bears the burden of demonstrating that the challenged evidence is inadmissible ‘on any relevant ground.’” Apotex, Inc. v. Cephalon, Inc., No. 2:06-CV-2768, 2017 WL 2362400, at *2 (E.D. Pa. May 31, 2017) (quoting Leonard, 981 F. Supp. 2d at 276).

IV. DISCUSSION Though Torchia’s revised report generally complies with the Court’s prior order because it does not discuss the caselaw or relevant legal standard, Defendant again moves to exclude Torchia’s revised report and testimony. Plaintiff still offers Torchia’s report as a means to show that Defendant’s internal investigation was carried out in a manner that impeded “the discovery of serious and significant harassment.” Knabe, 114 F.3d at 414.

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