Priscilla Giuseffi v. Sec US Dept Homeland Sec

CourtCourt of Appeals for the Third Circuit
DecidedApril 23, 2020
Docket19-2411
StatusUnpublished

This text of Priscilla Giuseffi v. Sec US Dept Homeland Sec (Priscilla Giuseffi v. Sec US Dept Homeland Sec) 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
Priscilla Giuseffi v. Sec US Dept Homeland Sec, (3d Cir. 2020).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT _______________

No. 19-2411 _______________

PRISCILLA GIUSEFFI, Appellant v.

SECRETARY UNITED STATES DEPARTMENT OF HOMELAND SECURITY _______________

On Appeal from the United States District Court for the Eastern District of Pennsylvania (D.C. No. 2:18-cv-00622) District Judge: Honorable Gerald J. Pappert _______________

Submitted Under Third Circuit L.A.R. 34.1 on January 31, 2020

Before: CHAGARES, RESTREPO, and BIBAS, Circuit Judges

(Filed: April 23, 2020) _______________

OPINION* _______________

* This disposition is not an opinion of the full Court and, under I.O.P. 5.7, is not binding precedent. BIBAS, Circuit Judge.

Retaliation claims require knowledge and action—in that order. One cannot retaliate

without first knowing that the target engaged in protected activity. Priscilla Giuseffi claims

that the federal government rescinded her job offer in retaliation for her complaint about

her previous firing. But the record shows that Janice Barlow, the official responsible for

making and rescinding that job offer, did not know about the prior complaint until after she

decided to pull the offer. Without Barlow’s prior knowledge of Giuseffi’s complaint,

Giuseffi cannot show that Barlow fired her because of the complaint. So there was no evi-

dence of causation and the District Court properly granted summary judgment. We will

thus affirm.

I. BACKGROUND

A. The rescinded job offer

On appeal from this summary judgment against Giuseffi, we view the facts in the light

most favorable to her: Giuseffi used to work as a Disaster Reservist for the Chicago office

of the Federal Emergency Management Agency (FEMA). In October 2010, FEMA fired

her for refusing to accept two deployments. After losing her internal appeal, she filed a

complaint with the Equal Employment Opportunity Commission (EEOC). She alleged that

by firing her, FEMA had discriminated against her on account of her disability and retali-

ated against her for filing a prior complaint.

While that complaint was pending, she applied for a new job with FEMA’s Philadelphia

office. On her application and in her interviews, she did not disclose that she had been fired

by FEMA’s Chicago office. Nor did she tell anyone in the Philadelphia office that she had

2 filed a complaint with the EEOC after she was fired. So Janice Barlow, the Philadelphia

FEMA official who recommended hiring her, did so under the impression that Giuseffi was

still working in the Chicago office. Barlow also did not yet know that Giuseffi had filed a

discrimination complaint. In November 2011, the Philadelphia office offered her the job.

Giuseffi then submitted a Form 306 to FEMA’s central human-resources office in Vir-

ginia, not Philadelphia. On that form, Giuseffi disclosed, for the first time, that she had

been fired and had filed a complaint with the EEOC. But nobody in Philadelphia was aware

of it yet.

After accepting the offer, Giuseffi contacted Kenneth Ragozzino, a FEMA human-

resources specialist who reported to Barlow in Philadelphia, to postpone her start date. As

he had no indication otherwise, Ragozzino thought that Giuseffi still worked for FEMA

and wondered if she could use her annual leave time to delay her start date. So he reached

out to FEMA’s central human-resources team in Virginia to see how much leave time she

had accrued.

On December 29th, the Virginia office responded that Giuseffi no longer worked for

FEMA and sent him her “termination packet.” App. 96. The packet included her termina-

tion notice and her internal appeal to FEMA. But it did not mention her discrimination

complaint to the EEOC.

Ragozzino immediately reported this information to Barlow. Until then, she too was

unaware that Giuseffi was not an active FEMA employee. As soon as she found this out,

Barlow decided to rescind Giuseffi’s offer. Barlow considered her firing from the Chicago

3 office “significant”; she would not risk rehiring someone whom FEMA had just fired. App.

90. Still, at this point, Barlow still did not know that Giuseffi had filed an EEOC complaint.

In a classic example of bureaucratic delegation, Barlow told Ragozzino to have the

Virginia office call Giuseffi and give her the bad news. So later that same day, at

12:40 p.m., Ragozzino emailed the Virginia office, asking how to “move forward expedi-

tiously in rescinding the final offer” and whether that could be done “today.” App. 125.

Then, at 3:31 p.m., he confirmed that “[r]egional management [that is, Barlow] does want

to move forward to rescind the offer” and would “prefer to do so today” by phone. App. 124

(emphasis in original).

At 3:46 p.m., Ragozzino heard back from Katie Short, a human-resources employee in

the Virginia office, with some new information. She had found Giuseffi’s Form 306 and

told Ragozzino that Giuseffi had lodged “[a] formal complaint” with the EEOC challenging

her firing. App. 221. Short heard nothing further from the Philadelphia office. Just before

3:57 p.m., she called and then emailed Giuseffi to rescind her job offer. Afterwards, Ragoz-

zino emailed Barlow to confirm that the Virginia office had rescinded the offer.

Years later, in 2014, an EEOC administrative law judge ruled for Giuseffi, finding that

the Chicago office had retaliated against her when it fired her in 2010.

B. Procedural history

After Barlow rescinded the job offer, Giuseffi filed another EEOC complaint under

Title VII. See 42 U.S.C. § 2000e–3(a) (prohibiting an employer from discriminating against

an employee who “has made a charge”). She alleged that the Philadelphia office had re-

scinded her job offer in retaliation for her prior complaint against the Chicago office. A

4 different administrative law judge held a hearing and denied the complaint, finding no

prima facie case of discrimination.

Giuseffi then filed suit in the District Court. The Court granted summary judgment for

the Government and denied Giuseffi’s motion to alter or amend the judgment.

Giuseffi now appeals both orders. We review the grant of summary judgment de novo.

Cranbury Brick Yard, LLC v. United States, 943 F.3d 701, 708 (3d Cir. 2019). And we

review the denial of the motion to alter or amend the judgment for abuse of discretion,

except that we review any questions of law de novo. Cureton v. NCAA, 252 F.3d 267, 272

(3d Cir. 2001).

II. GIUSEFFI CANNOT SHOW THAT HER PRIOR COMPLAINT CAUSED BARLOW TO RESCIND HER JOB OFFER

To defeat summary judgment, Giuseffi must show that she engaged in a protected ac-

tivity, she later suffered an adverse employment action, and there was a causal link between

the protected activity and the employer’s action. LeBoon v. Lancaster Jewish Cmty. Ctr.

Ass’n, 503 F.3d 217, 231–32 (3d Cir. 2007). The Government contests only causation. So

Giuseffi must show a genuine, material dispute about whether her prior wrongful-

termination complaint (the protected activity) caused Barlow to rescind her job offer (the

adverse action).

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