McLaughlin, R. v. Juniata College

CourtSuperior Court of Pennsylvania
DecidedMarch 11, 2022
Docket824 MDA 2021
StatusUnpublished

This text of McLaughlin, R. v. Juniata College (McLaughlin, R. v. Juniata College) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McLaughlin, R. v. Juniata College, (Pa. Ct. App. 2022).

Opinion

J-S01028-22

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT I.O.P. 65.37

RONALD MCLAUGHLIN : IN THE SUPERIOR COURT OF : PENNSYLVANIA Appellant : : : v. : : : JUNIATA COLLEGE : No. 824 MDA 2021

Appeal from the Order Entered May 11, 2021 In the Court of Common Pleas of Huntingdon County Civil Division at No(s): 2019-01339

BEFORE: BOWES, J., NICHOLS, J., and COLINS, J.*

MEMORANDUM BY NICHOLS, J.: FILED: MARCH 11, 2022

Appellant Ronald McLaughlin appeals pro se from the order granting the

motion for summary judgment filed by Appellee Juniata College and denying

Appellant’s motion for partial summary judgment. Appellant contends that

material issues of fact exist regarding whether Appellee breached the parties’

employment contract. We affirm.

We adopt the facts set forth in the trial court’s opinion. Trial Ct. Op.,

5/11/21, at 1-5. To briefly summarize, Appellant was a tenured professor

under an employment contract with Appellee. The parties’ employment

contract is comprised of Appellee’s (1) Faculty Handbook; (2) April 17, 2000

letter granting Appellant tenured status; and (3) August 30, 2018 letter

____________________________________________

* Retired Senior Judge assigned to the Superior Court. J-S01028-22

confirming Appellant’s employment for the 2018-2019 academic year. See

Ex. M to Appellee’s Suppl. Br. in Resp. to Appellant’s Suppl. to Mot. for Summ.

J., 2/22/21 (Appellee’s complete Faculty Manual); S.R.R. at 154b, 156b.1

Appellee’s Faculty Handbook defines “sick leave” as follows:

2.13.1.2 Sick Leave

In case of illness or disability during the academic year on the part of regular, full-time faculty members, salary payments are made as follows:

a. During the first month of illness the eligible faculty member receives the full salary applicable at the time of the onset of the illness or disability.

b. After the first month of illness or disability the eligible faculty member receives 85% of the salary applicable for the period dependent upon his or her length of service at Juniata. During the first year of a faculty appointment the 85% salary payments will be made for one month beyond the first month; during the second year for two months; during the third year for three months; during the fourth year for four months; up to a maximum of five months for persons who have been at Juniata five years or more.

c. These sick leave benefits are not cumulative and are based on the number of weeks missed in any given academic year.

S.R.R. at 149b;2 see also Ex. M to Appellee’s Suppl. Br. in Resp. to Appellant’s

Suppl. to Mot. for Summ. J., 2/22/21 (Appellee’s complete Faculty Manual).

1 We may cite to the parties’ initial, amended, or supplemental reproduced record for the parties’ convenience. We also cited to the reproduced record when there was no dispute as to whether a particular document was part of the certified record. 2As discussed below, one of the issues is whether the “sick leave” set forth herein is equivalent to “short term disability leave” or “medical leave.”

-2- J-S01028-22

The Faculty Manual does not explicitly reference unlimited paid leave, “short

term disability leave,” or “medical leave,” but does permit unpaid leave for

up to one year. See Ex. M to Appellee’s Suppl. Br. in Resp. to Appellant’s

Suppl. to Mot. for Summ. J.; S.R.R. at 151b.

In 2017, students complained about Appellant’s instruction, classroom

behavior, and student interactions. Trial Ct. Op. at 2. Appellee investigated,

substantiated the students’ complaints, and as a result, attempted to

introduce classroom observers into Appellant’s classroom to evaluate

Appellant’s teaching performance. Id. at 2-4. Appellant disagreed with

Appellee and did not cooperate with Appellee’s attempts to have classroom

observers. Id. at 4.

Shortly thereafter, Appellant proposed an accommodation under the

Americans with Disabilities Act3 (ADA), reasoning that because of his lupus,

3 42 U.S.C. § 12101-12213. In Allen v. State Civil Servs. Comm’n, 992 A.2d 924 (Pa. Cmwlth. 2010), the Court briefly summarized the ADA:

if a person wants and/or needs a reasonable accommodation to successfully perform a job, one must first have a disability, one must then inform the employer of the existence of the disability, and to the extent that one wants/needs a reasonable accommodation related to the disability, one should request a reasonable accommodation. Thereafter, with the assistance of the employer, one must decide what would be a reasonable accommodation under the circumstances.

Allen, 992 A.2d at 931. Decisions of the Commonwealth Court are not binding on this Court but we may rely on them for their persuasive value. NASDAQ OMX PHLX, Inc. v. PennMont Secs., 52 A.3d 296, 308 n.7 (Pa. Super. (Footnote Continued Next Page)

-3- J-S01028-22

he could not have classroom observers present while he taught. Id. at 5.

Appellee responded that it could not agree to Appellant’s proposed ADA

accommodation because refusing classroom observers was “contrary to an

essential function of [Appellant’s] job” as a professor. Id.4

Eventually, on August 24, 2018, Appellee placed Appellant on “medical

leave at full pay effective immediately, pending further review of [Appellant’s]

medical issues.” Id. at 6; see also Ex. I to Appellee’s Resp. to Appellant’s

Mot. for Partial Summ. J.; A.R.R. at 1a.5 Subsequently, the parties continued

to communicate regarding the proposed ADA accommodation and medical

2012) (citations omitted). Similarly, although federal court decisions do not bind this Court, we follow the precedent of federal courts within the Third Circuit whenever possible. See id. at 303. 4 Briefly, under the ADA, an employee must still be able to perform the essential functions of the job with or without the requested accommodation. Gardner v. SEPTA, 410 F. Supp. 3d 723, 739 (E.D. Pa. 2019). 5 For the sake of completeness, we quote the relevant passages from Appellee’s August 24, 2018 letter to Appellant:

[Appellant’s doctor] has opined that you [i.e., Appellant,] can only work provided that there are no uninvited visitations from either administrators or faculty members [i.e., the classroom observers]. . . . Effective teaching of [Appellee’s] students is an essential function of your job as a professor. To permit the accommodation you request could affect the education of students. Therefore, since your requested accommodation is contrary to an essential function of your job, this accommodation will not be granted. In the best interest of you and your health, I am placing you on medical leave at full pay effective immediately, pending further review of your medical issues. . . .

A.R.R. at 1a.

-4- J-S01028-22

leave. See Trial Ct. Op. at 7. On October 15, 2018, Appellee informed

Appellant as follows:

We also wish to confirm that your medical leave at full salary is being counted as your short term disability benefit under the Policy of the College. This short term disability benefit has a maximum benefit of six months at full salary. At the end of the six months, you will be eligible to file for long term disability through the insurance carrier of the College.

S.R.R. at 195b.6

On January 30, 2019, Appellee notified Appellant that his short term

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Federal Aviation Administration v. Cooper
132 S. Ct. 1441 (Supreme Court, 2012)
Allen v. State Civil Service Commission
992 A.2d 924 (Commonwealth Court of Pennsylvania, 2010)
Baker v. Lafayette College
504 A.2d 247 (Supreme Court of Pennsylvania, 1986)
Murphy v. Duquesne University of Holy Ghost
777 A.2d 418 (Supreme Court of Pennsylvania, 2001)
Nicholas, J. v. Hofmann, D.
158 A.3d 675 (Superior Court of Pennsylvania, 2017)
Trombetta v. Raymond James Financial Services, Inc.
907 A.2d 550 (Superior Court of Pennsylvania, 2006)
Nasdaq Omx Phlx, Inc. v. Pennmont Securities
52 A.3d 296 (Superior Court of Pennsylvania, 2012)
Ruspi v. Glatz
69 A.3d 680 (Superior Court of Pennsylvania, 2013)
Garner v. School District
63 F. Supp. 3d 483 (E.D. Pennsylvania, 2014)
Solomon v. School District of Philadelphia
882 F. Supp. 2d 766 (E.D. Pennsylvania, 2012)
TTSP Corp. v. The Rose Corp.
2019 Pa. Super. 262 (Superior Court of Pennsylvania, 2019)
Liberty Mutual Group v. 700 Pharmacy, LLC
2022 Pa. Super. 19 (Superior Court of Pennsylvania, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
McLaughlin, R. v. Juniata College, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mclaughlin-r-v-juniata-college-pasuperct-2022.