Patricia Fritz v. County of Westmoreland

CourtCourt of Appeals for the Third Circuit
DecidedFebruary 27, 2024
Docket22-2999
StatusUnpublished

This text of Patricia Fritz v. County of Westmoreland (Patricia Fritz v. County of Westmoreland) 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
Patricia Fritz v. County of Westmoreland, (3d Cir. 2024).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT _________________

No. 22-2999 _________________

PATRICIA FRITZ, Appellant

v.

COUNTY OF WESTMORELAND; SHERIFFS DEPARTMENT OF WESTMORELAND COUNTY; SHERIFF JONATHAN HELD, in his individual and representative capacity; CHARLES ANDERSON, in his individual and representative capacity; GINA CERILLI, in her individual and representative capacity; TED KOPAS, in his individual and representative capacity; DAVID REGOLI, in his individual and representative capacity ________________

On Appeal from the United States District Court for the Western District of Pennsylvania (D.C. Civil No. 2-19-cv-01517) District Judge: Honorable William S. Stickman, IV ________________

Submitted Under Third Circuit L.A.R. 34.1(a) on October 27, 2023

Before: HARDIMAN, FREEMAN, and MONTGOMERY-REEVES, Circuit Judges.

(Opinion filed: February 27, 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. MONTGOMERY-REEVES, Circuit Judge.

In May 2014, Sheriff Jonathan Held appointed Patricia Fritz to serve as chief

deputy sheriff for Westmoreland County (the “County”). After several issues in the

Sheriff’s Office and with Fritz specifically, the County Commissioners fired Fritz.

After her termination, Fritz sued the County, Held, the Sheriff’s Office, County

Commissioner Charles Anderson, County Commissioner Ted Kopas, County

Commissioner Gina Cerilli, and Westmoreland County Assistant Solicitor David Regoli

(collectively, “Appellees”). Fritz alleged, among other things, that Appellees

discriminated against her based on her political beliefs, in violation of the First

Amendment; discriminated against her on the basis of her sex, in violation of state and

federal law; and retaliated against her for complaining about illegal discrimination, in

violation of state and federal law.

The District Court ruled against Fritz on each of these claims. Because we agree

with the District Court that Fritz failed to allege causation and that she failed to show that

reconsideration was warranted, we will affirm the District Court’s dismissal of Fritz’s

First Amendment claim and denial of her motion for reconsideration on that claim. We

also will affirm the District Court’s disposition of the remaining claims because, even

assuming Fritz established a prima facie case, Appellees provided a legitimate reason for

her termination, which Fritz has not shown was pretextual.

2 I. BACKGROUND 1

From 2014 to 2018, Fritz served as the County’s chief deputy sheriff. There was

friction throughout Fritz’s tenure, but tensions reached a boiling point in 2018. First, in

early 2018, three different people threatened to sue the County and the Sheriff’s Office

for engaging in racial discrimination, including specific allegations against Fritz. Among

other things, they alleged that Fritz did not want a Black woman hired because she had

worked with Black individuals previously and found that they “were nothing but

trouble.” J.A. 1204. Then, in August 2018, Fritz had a physical altercation with a

subordinate deputy sheriff. After the altercation, Held suspended Fritz with pay. The

County hired an attorney to perform an independent investigation. The attorney

concluded that Fritz’s conduct during the altercation was unacceptable and recommended

that the County terminate Fritz. Separately, the district attorney’s office criminally

charged Fritz with summary harassment, for which she was convicted. 2

Held was the only person with the statutory authority to terminate Fritz. But Held

believed that he had a conflict of interest in deciding whether to terminate Fritz because

he “was a witness . . . in the criminal case.” J.A. 805–06. Thus, Held delegated his

authority to the County Commissioners, who terminated Fritz on October 25, 2018. In a

1 We write for the benefit of the parties and recite only essential facts. 2 Ultimately, Fritz’s conviction was overturned on appeal on August 22, 2019. During this time, Fritz also filed or amended several EEOC complaints against Appellees.

3 letter, the County stated that it decided to terminate Fritz for several reasons, including

that:

• “On August 7, 2018, it is alleged that you yelled at, pushed, and poked an employee following a meeting[,] . . . . that you blocked the employee from leaving the room[, and] that you then yelled at and followed the employee through public areas.” J.A. 1083.

• “On August 22, 2018, you were charged with a citation for harassment.” Id.

• “On October 2, 2018, you were found guilty of a summary harassment charge stemming from this incident.” Id.

• “Our investigation concluded that your behavior constituted a violation of the Westmoreland County Workplace Violence Policy and the Westmoreland County Code of Ethics.” Id.

• “[T]he behavior and charge of harassment is a violation of the Westmoreland County Sheriffs Policy Manual in regards to Article V, Section 2 and Section 4.” Id.

• “[T]he County is aware of allegations of racial discrimination made by several former County employees. These concerns relate to a pattern of racial discrimination in hiring.” Id.

Fritz sued Appellees. Relevant to this appeal, Fritz alleged violations of her First

Amendment right to political affiliation against the County, Cerilli, Kopas, and Regoli in

violation of 42 U.S.C. § 1983 (Count VII), and she alleged sex discrimination and

retaliation in violation of Pennsylvania and federal law against Appellees (Counts I, II,

VI, VIII). 3

3 Fritz did not appeal the District Court’s dismissal of the individual or official capacity § 1983 claims (Counts VI and VII) or the dismissal of the claims that she brought under the Pennsylvania Human Relations Act against appellees Anderson, Cerilli, Kopas, and Regoli. Likewise, Fritz does not appeal the District Court’s summary judgment in favor

4 The District Court dismissed Fritz’s First Amendment claim and allowed the other

claims to proceed to discovery. Fritz filed a motion for reconsideration based on

deposition testimony that she claimed constituted newly discovered evidence. The

District Court denied her motion.

At the close of discovery, Appellees moved for summary judgment on each of

Fritz’s remaining claims, including her sex-discrimination and retaliation claims. The

District Court granted Appellees’ motion for summary judgment. Fritz appealed.

II. DISCUSSION 4

On appeal, Fritz challenges three rulings: (1) the District Court’s order dismissing

her First Amendment claim (Count VII); (2) the District Court’s order denying her

motion for reconsideration on her First Amendment claim; and (3) the District Court’s

order granting summary judgment on her sex-discrimination and retaliation claims

(Counts I, II, VI, VIII). We address each challenge below.

of Appellees on her age discrimination claims (Count III, Count VIII, in part) and Equal Pay Act claims (Counts IV and V). Thus, we do not discuss those claims further. 4 The District Court had jurisdiction over this case under 28 U.S.C. § 1331. We have jurisdiction over this appeal under 28 U.S.C. §

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Patricia Fritz v. County of Westmoreland, Counsel Stack Legal Research, https://law.counselstack.com/opinion/patricia-fritz-v-county-of-westmoreland-ca3-2024.