POOLE v. COUNTY OF ALLEGHENY

CourtDistrict Court, W.D. Pennsylvania
DecidedJune 2, 2025
Docket2:23-cv-01843
StatusUnknown

This text of POOLE v. COUNTY OF ALLEGHENY (POOLE v. COUNTY OF ALLEGHENY) is published on Counsel Stack Legal Research, covering District Court, W.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
POOLE v. COUNTY OF ALLEGHENY, (W.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA PITTSBURGH

STACEY POOLE, ) )

) 2:23-CV-01843-MJH Plaintiff, )

) vs. )

) COUNTY OF ALLEGHENY, ) ) Defendant,

MEMORANDUM OPINION On December 19, 2024, Plaintiff, Stacey Poole, brought a three-count Second Amended Complaint against Defendant, Allegheny County, alleging claims under Title VII of the Civil Rights Act of 1964 (“Title VII”) and the Pennsylvania Human Relations Act (“PHRA”), as well as a claim for wrongful discharge. (ECF No. 26). On January 2, 2025, Defendant filed a Motion to Dismiss the Second Amended Complaint and accompanying brief. (ECF Nos. 27 & 28). Plaintiff did not respond to Defendant’s Motion to Dismiss. For the following reasons, Defendant’s Motion to Dismiss will be granted in full. I. Statement of Facts Throughout the COVID-19 pandemic, Allegheny County enacted policies and practices that were designed to halt the spread of COVID-19. These policies and practices were based on available data and public-health guidance at the time that they were enacted. (ECF No. 28-1). At first, Allegheny County implemented masking and social distancing practices. (Id.). On August 5, 2021, in addition to the masking and social distancing practices, Allegheny County announced that all employees who did not have their COVID-19 vaccination were required to undergo weekly COVID-19 testing. (Id.) On September 29, 2021, Allegheny County announced that it was implementing a COVID-19 vaccine mandate (“vaccine mandate”) for all County employees under the Executive branch. (Id.) The vaccine mandate stated that “all Allegheny County employees under the Executive branch must have received their second dose of a two-dose

COVID-19 vaccine or a one-dose vaccine” on or before December 1, 2021. (Id.) The mandate allowed for exceptions as “required by law” and further stated that “employees who fail to submit proof of completed vaccination by December 1, 2021 (without an approved accommodation) will be subject to termination of employment. (Id.). Plaintiff, Stacey Poole, was employed by Allegheny County as a dental assistant. (ECF No.

28, at ¶ 18). After Allegheny County announced its vaccination mandate, “Plaintiff told her employer about her Factor 5 blood clotting disorder and how she was afraid of the vaccine, known to cause clotting, could cause her serious injury and/or death.” (Id. ¶ 20). Plaintiff asked to be exempt from the vaccine mandate and Defendant rejected Plaintiff’s exemption request. (Id. ¶ 26). On December 11, 2021, Plaintiff was terminated for failure to comply with the vaccination requirement. (Id. ¶ 24).

II. Relevant Legal Standard When reviewing a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6), the court must “accept all factual allegations as true, construe the complaint in the light most favorable to the plaintiff, and determine whether, under any reasonable reading of the complaint, the plaintiff may be entitled to relief.” Eid v. Thompson, 740 F.3d 118, 122 (3d Cir. 2014) (quoting Phillips v. Cty. of Allegheny, 515 F.3d 224, 233 (3d Cir. 2008)). “To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). The Supreme Court clarified that this plausibility standard should not be conflated with a higher probability standard. Iqbal, 556 U.S. at 678. “A claim has facial plausibility when the

plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678 (citing Twombly, 550 U.S. at 556); see also Thompson v. Real Estate Mortg. Network, 748 F.3d 142, 147 (3d Cir. 2014). “Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Iqbal, 556 U.S. at 678. “Factual allegations of a complaint must be enough to raise a right to relief above the speculative level.” Twombly, 550 U.S. at 555. A pleading party need not establish the elements of a prima facie case at this stage; the party must only “put forth allegations that ‘raise a reasonable expectation that discovery will reveal evidence of the necessary element[s].’” Fowler v. UPMC Shadyside, 578 F.3d 203, 213 (3d Cir.

2009) (quoting Graff v. Subbiah Cardiology Assocs., Ltd., 2008 WL 2312671 (W.D. Pa. June 4, 2008)); see also Connelly v. Lane Constr. Corp., 809 F.3d 780, 790 (3d Cir. 2016). Nonetheless, a court need not credit bald assertions, unwarranted inferences, or legal conclusions cast in the form of factual averments. Morse v. Lower Merion Sch. Dist., 132 F.3d 902, 906 n.8 (3d Cir. 1997). The primary question in deciding a motion to dismiss is not whether the plaintiff will ultimately prevail, but whether he or she is entitled to offer evidence to establish the facts alleged in the complaint. Maio v. Aetna, 221 F.3d 472, 482 (3d Cir. 2000). The purpose of a motion to dismiss is to “streamline[] litigation by dispensing with needless discovery and factfinding.” Neitzke v. Williams, 490 U.S. 319, 326-27 (1989). III. Discussion A. Title VII and PHRA Claims

Defendant argues that Plaintiff failed to exhaust her administrative remedies with the EEOC, and the PHRC, and thus her Title VII and PHRA claims must be dismissed. (ECF No. 28, at 4- 12). In Plaintiff’s Second Amended Complaint she alleges that she “is entitled to piggyback on the Complaint filed by Shane Chesher,” and any other Allegheny County employee, that brought similar claims as her against Defendant, to satisfy her requirement to exhaust her administrative remedies under the respective statutes. (ECF No. 26, at ¶¶ 2a-f). Plaintiff further alleges that the equitable tolling doctrine applies, and she does not need to exhaust her administrative remedies.

Before an action can be filed in federal court under the ADA, Title VII, or the PHRA, a plaintiff must exhaust their administrative remedies by filing a charge with the EEOC. Robinson v. Dalton, 107 F.3d 1018, 1020 (3d Cir. 1997) (holding that “[t]o plead a claim under Title VII, ‘a plaintiff must exhaust all required administrative remedies’”; Churchill v. Star Enterprises, 183 F.3d 184, 190 (3d Cir.1999) (holding that “the ADA and the PHRA require pursuit of administrative remedies before a plaintiff may file a complaint in court”). Plaintiff’s failure to comply with this administrative requirement constitutes failure to exhaust administrative remedies and provides sufficient ground to dismiss her claims under the ADA, Title VII and the PHRA. Ganaway v. City of Pittsburgh, 2008 WL 336297 (2008 W.D. Pa.) (holding that failure

to exhaust administrative remedies bars any applicable causes of action).

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POOLE v. COUNTY OF ALLEGHENY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/poole-v-county-of-allegheny-pawd-2025.