Pratt v. Science Applications International Corporation

CourtDistrict Court, E.D. Virginia
DecidedSeptember 24, 2025
Docket1:23-cv-00417
StatusUnknown

This text of Pratt v. Science Applications International Corporation (Pratt v. Science Applications International Corporation) is published on Counsel Stack Legal Research, covering District Court, E.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pratt v. Science Applications International Corporation, (E.D. Va. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division PATTY PRATT, ) Plaintiff, v. Civil Action No. 1:23-cv-417 (RDA/LRV) SCIENCE APPLICATIONS INTERNATIONAL CORPORATION, ) Defendant. ) MEMORANDUM OPINION AND ORDER This matter comes before the Court on Defendant Science Application International Corporation’s (“SAIC” or “Defendant”) Motion for Partial Summary Judgment (the “Motion”). Dkt. 42. This Court has dispensed with oral argument as it would not aid in the decisional process. See Fed. R. Civ. P. 78(b); Local Civil Rule 7(J). This matter has been fully briefed and is now ripe for disposition. Considering the Motion together with Defendant’s Memorandum in Support (Dkt. 43), Plaintiff Patty Pratt’s Opposition (Dkt. 47), and Defendant’s Reply (Dkt. 48), this Court GRANTS the Motion for the reasons that follow.

I. PROCEDURAL BACKGROUND On March 29, 2023, Plaintiff filed her Complaint in this action asserting five counts of disability discrimination under the Americans with Disabilities Act (“ADA”). Dkt. 1. On May 12, 2023, Defendant filed its Answer. Dkt. 8. Thereafter, a Scheduling Order was issued, and the case proceeded to discovery. Dkt. 9. On October 3, 2023, Defendant filed its first motion for summary judgment. Dkt. 26. On September 11, 2024, the Court issued its Memorandum Opinion and Order granting in part and denying in part that motion. Dkt. 41. In analyzing Counts 3 and 4 with respect to the first motion,

the Court recognized that Plaintiffs claims of disability discrimination and retaliation under the Americans with Disabilities Act (the “ADA”) based on being forced to take leave related to two separate time periods: (i) a period from May 28, 2021 through June 28 and “early” July; and (ii) a period from July 30, 2021 through the conclusion of Plaintiff's employment. Dkt. 41 at 12. The Court held that the first period was outside of the 300-day lookback period for the ADA and thus time-barred, but that the second period was not. Jd. The Court noted that Defendant’s other argument regarding whether Counts 3 and 4 should be dismissed was only contained within a footnote and that the Fourth Circuit disfavors ruling on dispositive issues based on arguments contained in a footnote. Jd. Thus, the Court denied the motion on that basis without prejudice and with leave to renew that argument so as to put Plaintiff on notice regarding the importance of the issue and to permit Plaintiff to specifically address it. Jd. In essence, the Court directed that there be supplemental briefing on that issue, but limited the briefing to the facts determined by the Court in the Memorandum Opinion and Order. /d. at 13. The Court otherwise granted the motion. Jd. at 25-26. On September 27, 2024, with leave of Court as provided in the Memorandum Opinion and Order, Defendant filed its renewed motion (the pending Motion). Dkt. 42. On October 11, 2024, Plaintiff responded in Opposition. Dkt. 47. On October 18, 2024, Defendant filed its Reply. Dkt. 48. II. LEGAL STANDARD Summary judgment is appropriate only if “the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a); see also Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 247-48 (1986). The party seeking summary judgment has the initial burden to show the absence of a material fact. Celotex

Corp. v. Catrett, 477 U.S. 317, 325 (1986). The facts shall be viewed, and all reasonable inferences drawn, in the light most favorable to the non-moving party. Anderson, 477 U.S. at 255. “(A) party opposing summary judgment may not simply rest on the allegations of his complaint, but must instead come forward with specific evidence showing the existence of a genuine issue of fact.” Muhammad v. Giant Food, 108 F. App’x 757, 764 (4th Cir. 2004) (citing Williams v. Griffin, 952 F.2d 820, 823 (4th Cir. 1991)). Ill. ANALYSIS As the Court previously indicated, the Court relies on only those facts that the Court determined were undisputed in its prior Memorandum Opinion and Order. Dkt. 41. By way of summary of those facts, this case arises out of the COVID-19 pandemic and the response thereto. Plaintiff worked for Defendant as a government contractor on a contract with the National Reconnaissance Office (the “NRO”), and that work required that Plaintiff work in a Sensitive Compartmented Information Facility (““SCIF”). /d. at 3-4. Relevant to the remaining claims at issue here, on July 22, 2021, the NRO issued a policy that required “all unvaccinated personnel to wear a mask at all times while on NRO or NRO-occupied property.” Jd. at 6. On July 25, 2021, Plaintiff submitted an accommodation request to not wear a mask (as she was unvaccinated) and, on July 30, 2021, Plaintiff was told that she could either (1) take leave or (2) charge the time to a COVID admin code and later make up that admin time. /d. at 7. In its Motion, Defendant now renews its motion for summary judgment with respect to Count 3, which asserts ADA disability discrimination based on Defendant requiring Plaintiff to take leave, and Count 4, which asserts ADA retaliation based on Defendant requiring Plaintiff to take leave. Plaintiff opposes summary judgment. Defendant’s arguments with respect to each Count will be addressed below.

A. Whether the Motion was Properly Renewed As an initial matter, this Court must address Plaintiff's argument that the Motion is not well taken because it renews arguments previously made. Dkt. 47 at 2. As judges in this District have long recognized, “[t]his Court has discretion to allow [Defendant] to renew its Motion.” Abella v. Universal Leaf Tobacco Co., Inc., 546 F. Supp. 795, 797 (E.D. Va. 1982). Other courts have reached the same conclusion. See, e.g., Whitford v. Boglino, 63 F.3d 527, 530 (7th Cir. 1995) (“[T]he denial of summary judgment has no res judicata effect, and the district court may, in its discretion, allow a party torenewa previously denied summary judgment motion or file successive motions, particularly if good reasons exist.”). Plaintiff cites no authority holding that this is not a matter of discretion. Rather, Plaintiff cites a number of cases where courts have exercised their discretion not to consider or invite additional arguments or supplemental briefing □ this case law does not stand for the proposition that such renewal is improper or unfair. Dkt. 47 at 2 (citing cases). Indeed, Plaintiff misunderstands the basis for the Court’s prior holding. The basis for the Court’s decision was not that Defendant had not raised the issue such that it was available for decision, but that Plaintiff was not properly on notice that she had to respond to it and, thus, it was unfair to decide a dispositive issue without the opportunity for full briefing by Plaintiff. Dkt. 41 at 12-13. Accordingly, this is not a basis on which to deny the renewed Motion. B.

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Bluebook (online)
Pratt v. Science Applications International Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pratt-v-science-applications-international-corporation-vaed-2025.