PEIFER v. COMMONWEALTH OF PENNSYLVANIA, PENNSYLVANIA BOARD OF PROBATION AND PAROLE

CourtDistrict Court, E.D. Pennsylvania
DecidedJanuary 5, 2023
Docket2:21-cv-05432
StatusUnknown

This text of PEIFER v. COMMONWEALTH OF PENNSYLVANIA, PENNSYLVANIA BOARD OF PROBATION AND PAROLE (PEIFER v. COMMONWEALTH OF PENNSYLVANIA, PENNSYLVANIA BOARD OF PROBATION AND PAROLE) 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
PEIFER v. COMMONWEALTH OF PENNSYLVANIA, PENNSYLVANIA BOARD OF PROBATION AND PAROLE, (E.D. Pa. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

PEIFER. : CIVIL ACTION Plaintiff, : : v. : No. 21–5432 : COMMONWEALTH OF PENNSYLVANIA : PENNSYLVANIA BOARD OF : PROBATION AND PAROLE : Defendant. :

MEMORANDUM KENNEY, J. January 5, 2023 Before the Court is Defendant’s Motion for Summary Judgment against Plaintiff Samantha Peifer. ECF No. 20. Plaintiff’s Amended Complaint (ECF No. 3) includes surviving claims of gender and pregnancy-based discrimination and retaliation under Title VII of the Civil Rights Act of 1964. I. BACKGROUND Ms. Peifer brings this civil suit against her former employer the Commonwealth of Pennsylvania, Pennsylvania Board of Probation and Parole (hereinafter “the Board of Probation and Parole”) alleging disability, gender and pregnancy discrimination and retaliation. ECF No. 3. Ms. Peifer worked for the Board of Probation and Parole and was, at all times relevant to this matter, pregnant. According to Plaintiff, the Board of Probation and Parole is the Commonwealth’s agency that oversees criminal offenders who have been given early release. ECF No. 3 ¶ 3. Ms. Peifer started in the role of Parole Agent I in or around January 2016 and was promoted to Parole Agent II in or around July 2016. Id. ¶¶ 24-25. Plaintiff was diagnosed with Multiple Sclerosis (“MS”) in or around September 2019. Id. ¶ 27. Plaintiff describes this ailment as substantially limiting her walking, breathing, and ability to perform manual labor. Id. ¶ 28. Ms. Peifer informed her supervisor, Joseph Bentzley, of her diagnosis of MS. Id. ¶ 29. The Board of Probation and Parole granted Ms. Peifer intermittent

medical leave under the Family and Medical Leave Act (“FMLA”) as an accommodation for her disability. Id. ¶ 30. In or around March 2020, Ms. Peifer informed Mr. Bentzley, her direct supervisor, that she was pregnant with an expected due date in August 2020. Id. ¶ 31. Ms. Peifer also mentioned that she had a high-risk pregnancy due to her MS. Id. ¶ 32. Because of her disability and pregnancy, Ms. Peifer requested a modified duty assignment until the birth of her child. Id. ¶ 33. Plaintiff alleges that Mr. Bentzley initially denied her request because the Board of Probation and Parole does not provide accommodations for pregnancy. Id. ¶¶ 33-35. On March 15, 2020, Ms. Peifer again requested light duty and supplied Mr. Bentzley with documentation from her physician recommending light duty work. Id. ¶ 36. Ms. Peifer alleges that the following day she

was denied accommodation by Michelle Rivera, the Eastern Regional Director. Id. ¶ 39. On March 25, 2020, Ms. Peifer requested light duty work for a third time with updated medical documentation. Id. ¶ 41. That same day, Ms. Rivera allegedly denied Plaintiff’s request by email and called Plaintiff to “admonish[] her” for sending another request. Id. ¶¶ 43, 45. Ms. Peifer further alleges she was informed by both Michelle Rivera and Joseph Bentzley to stop working. Id. ¶¶ 46-47. Ms. Peifer claims she was then forced to take FMLA leave of absence. Id. ¶ 48. Nearly one month later, Plaintiff filed a Charge of Discrimination with the EEOC alleging disability, sex and pregnancy discrimination and retaliation against the Board of Probation and Parole. Id. ¶ 51. Plaintiff alleges that her employer retaliated against her for the EEOC Charge on or around May 18, 2020 by requiring her to work in the office full time and keep an inflexible schedule. Id. ¶ 54. Ms. Peifer claims she was the only person in her district forced to work solely in the office at that time. Id. ¶ 55, 59. Ms. Peifer also claims she was forced to use her personal vehicle instead of the state vehicle she used prior. Id. ¶ 56.

On May 28, 2020, Plaintiff requested an accommodation to work remotely or for the provision of personal protective equipment (“PPE”) and gave Mr. Bentzley documentation from her physician in support of this request. Id. ¶ 57. Mr. Bentzley allegedly mocked Plaintiff in front of her coworkers for using PPE. Id. ¶ 58. Plaintiff further complained that her front desk assignment was retaliatory and that it put her health and her unborn child’s health at risk. Id. ¶ 60. Plaintiff was later diagnosed with cholestasis of pregnancy, though it is unclear at what time Plaintiff became aware of this pregnancy complication or when her supervisor was notified of the condition. Id. ¶¶ 62-63. Plaintiff then filed a second Charge of Discrimination with the EEOC on June 26, 2020. Id. ¶ 65. Ms. Peifer claims her requests for remote work continued to be denied while others who

were not pregnant or disabled were able to work remotely or partially remote. Id. ¶ 68. On or around September 23, 2020, Ms. Peifer resigned from her position, alleging she was constructively discharged because of the Board of Probation and Parole’s failure to address discriminatory and retaliatory conduct. Id. ¶ 69. In their Motion for Summary Judgment (ECF No. 20) and attached Statement of Undisputed Material Facts (ECF No. 20-1), the Board of Probation and Parole asserts that Ms. Peifer was accommodated in accordance with her medical documentation and modified job responsibilities, and that Plaintiff voluntarily resigned. Plaintiff was employed as an Alcohol and Other Drugs agent in the Chester District Office since April 2018. ECF No. 20-1 ¶¶ 3-4. At the outset, Defendant admits there was a delay in approval of modified light duty when Plaintiff requested accommodation in March 2020. ECF No. 20 at 5. Plaintiff sent a note from her physician to her supervisor Mr. Bentzley formally requesting light duty on March 15, 2020. ECF No. 20-1 ¶ 8. The following day, Defendant stated it could not “approve light duty as

indicated within [Ms. Peifer’s] medical documentation.” Id. ¶ 9. Defendant instructed Plaintiff instead to contact the FMLA Coordinator. Id. On March 25, Plaintiff provided another physician’s note to Defendant, identifying which of her current job duties she was able and unable to perform. Id. ¶ 10. Defendant similarly responded that modified light duty was unavailable for any non-work-related injury and Plaintiff must contact the FMLA Coordinator if unable to meet the essential functions of her position. Id. ¶ 11. Plaintiff subsequently used FMLA and annual leave around March 26, 2020. Id. ¶ 12. However, Defendant did eventually grant Plaintiff a modified set of duties on May 14, 2020, which Ms. Peifer agreed to, even though it required work in the office. Id. ¶ 13. On May 13, 2020, Plaintiff emailed Defendant requesting further explanation for what accommodation

would be provided and Defendant responded that they could accommodate her request for modified duty and Ms. Peifer should return to work on May 18. Id. Defendant also paid Ms. Peifer in full for the time she was placed on leave between the end of March and mid-May 2020 and restored both her annual and sick leave time. Id. ¶ 16 Thereafter, on May 28, Plaintiff provided an additional physician’s note, requesting either work from home or PPE due to Ms. Peifer’s pregnancy. Id. ¶ 17. The Board of Probation and Parole elected to provide PPE to accommodate Ms. Peifer’s pregnancy because working at the front desk was her primary responsibility and work from home was not practicable. Id. The PPE included gloves, mask, and face shield. Id. On September 23, 2020, Ms. Peifer informed Defendant that she was resigning in response to discriminatory treatment and considered herself constructively discharged. Id. ¶ 19. II. PROCEDURAL HISTORY Plaintiff initiated this action on December 13, 2021. ECF No. 1. Ms. Peifer amended her

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Bluebook (online)
PEIFER v. COMMONWEALTH OF PENNSYLVANIA, PENNSYLVANIA BOARD OF PROBATION AND PAROLE, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peifer-v-commonwealth-of-pennsylvania-pennsylvania-board-of-probation-and-paed-2023.