REID v. VETERANS ADMINISTRATION, PITTSBURGH, PA

CourtDistrict Court, W.D. Pennsylvania
DecidedJune 30, 2025
Docket2:22-cv-01025
StatusUnknown

This text of REID v. VETERANS ADMINISTRATION, PITTSBURGH, PA (REID v. VETERANS ADMINISTRATION, PITTSBURGH, PA) 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
REID v. VETERANS ADMINISTRATION, PITTSBURGH, PA, (W.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA PITTSBURGH DIVISION GARRETT R. REID, ) Civil Action No. 2:22-CV-01025-CBB ) ) Plaintiff, ) ) United States Magistrate Judge vs. ) Christopher B. Brown ) VETERANS ADMINISTRATION, ) PITTSBURGH, PA, ) ) ) Defendant, )

MEMORANDUM OPINION1 ON DEFENDANT’S MOTION TO DISMISS, OR IN THE ALTERNATIVE, MOTION FOR SUMMARY JUDGMENT, ECF No. 14 I. Introduction Plaintiff Garrett R. Reid (“Reid”) initiated this pro se civil action alleging his employer, Defendant Veterans Administration, Pittsburgh, PA (“Defendant”), discriminated against him by failing to accommodate his traumatic brain injury after he returned from military service, in violation of Section 504 of the Rehabilitation Act, 29 U.S.C. § 794, et seq. (“the Rehabilitation Act”), Title VII of the Civil Rights Act of 1964, as amended 42 U.S.C. § 2000e, et seq. (“Title VII”), the Age Discrimination in Employment Act of 1967, as amended 29 U.S.C. § 621, et seq.

1 All parties have consented to jurisdiction before a United States Magistrate Judge; therefore the Court has the authority to decide dispositive motions, and to eventually enter final judgment. See 28 U.S.C. § 636, et seq. This matter was originally assigned to Magistrate Judge Cynthia Reed Eddy. Upon Judge Eddy’s retirement, the matter was reassigned on April 23, 2024, to Chief Magistrate Judge Richard A. Lanzillo. On July 3, 2024, by Administrative Order 2024-07 filed at 2:24-mc-10001, the matter was reassigned to this member of the Court. (“ADEA”), the Pennsylvania Human Relations Act, 43 P.S. § 951, et seq. (“PHRA”), and the Uniformed Services Employment and Reemployment Rights Act of 1994, 38 U.S.C. §§ 4301 to 4333 (“USERRA”). ECF No. 11. This court has subject matter

jurisdiction under 28 U.S.C. § 1331 for Reid’s federal claims.2 Presently pending before the Court is Defendant’s Motion to Dismiss, or in the alternative, Motion for Summary Judgment. ECF No 14. The Court converted the Motion to Dismiss to a Motion for Summary Judgment on the issue of exhaustion only. ECF No. 16. The Motion is fully briefed and ripe for consideration. ECF Nos. 14-15, 23, 28.

For the reasons set forth below, the Defendant’s Motion is GRANTED in part and DENIED in part as follows: • Defendant’s Motion to Dismiss for failure to state a claim with respect to Reid’s Rehabilitation Act disability discrimination and failure-to- accommodate claims is GRANTED without prejudice and with leave for Reid to amend. • Defendant’s Motion for Summary Judgment as to Reid’s exhaustion of administrative remedies for his Rehabilitation Act claims will be DENIED without prejudice for Defendant to reassert. • Defendant’s Motion to Dismiss for failure to state a claim with respect to Reid’s Title VII and ADEA claims is GRANTED without prejudice and with leave for Reid to amend. • Defendant’s Motion for Summary Judgment on Reid’s exhaustion of administrative remedies for his Title VII and ADEA claims will be DENIED without prejudice for Defendant to reassert.

2 Reid also brings a state law claim under the PHRA, which Defendant challenges for lack of subject matter jurisdiction. ECF No. 15 at 17. Defendant is correct that the Court lacks subject matter jurisdiction over Reid’s PHRA claim, as addressed infra. • Defendant’s Motion to Dismiss for lack of subject matter jurisdiction with respect to Reid’s PHRA claim is GRANTED with prejudice. • Defendant’s Motion to Dismiss for failure to state a claim with respect to Reid’s USERRA claim is GRANTED without prejudice and with leave for Reid to amend. Reid is granted thirty (30) days, or until July 30, 2025, to file an amended complaint addressing the deficiencies set forth below. This case will be marked as ADMINISTRATIVELY CLOSED unless and until Reid files the amended complaint by the specified deadline. II. Factual Background Reid alleges he was an employee of the Defendant Veteran’s Administration in the Aspinwall and Pittsburgh, PA locations. ECF No. 11 at 1. Following a leave of absence, he returned to work in 2019 when the Defendant’s Human Resources Department (“HR Department”) discriminated against him by failing to

accommodate his disability – specifically, a traumatic brain injury which he sustained while on military deployment in Syria. Id. Instead of accommodating him, Reid alleges the HR Department placed him on leave without pay for sixteen months, refused him 120 hours of disability leave, “dropped the ball on reasonable accommodation” twice, did not notify him that they dismissed his reasonable accommodation, and “completely ignored and discarded

him.” Id. at 4. He alleges the HR Department’s mishandling of his accommodation request made him unjustifiably compete for his employment. Id. Notably, Reid does not specify what his job was at the Veterans Affairs, nor what reasonable accommodations he requested. See generally, ECF No. 11. Nonetheless, he demands sixteen months of lost pay, a COVID-19 bonus, and compensation for lost training time, job credibility, and pain and suffering. Id. at 5. Prior to filing this action in federal court, Plaintiff contacted an Equal

Employment Opportunity (“EEO”) Counselor on April 13, 2021 regarding his allegations of discrimination. ECF No. 14-1 at 2-5. The EEO issued him a Notice of Right to File a Discrimination Complaint on May 11, 2021. ECF No. 14-2 at 2-6. Reid received access to the Notice on May 13, 2021, which triggered his 15-day window to file his formal complaint on or before May 28, 2021. Id. at 7. See also 29 C.F.R. § 1614.106. Reid filed his formal complaint on June 29, 2021. ECF No. 14-3

at 2. On September 9, 2021, the Department of Veterans Affairs Office of Resolution Management issued a final agency decision and dismissed Reid’s claims because they were raised beyond the 45-day reporting requirement, set forth in 29 C.F.R. § 1614.105 (a)(2), and because he filed his formal complaint beyond the 15- day filing period. 29 C.F.R. § 1614.106. ECF No. 14-3 at 2-10. Reid appealed the final agency decision to the Office of Federal Operations for the Equal Employment Opportunity Commission. ECF No. 14-4 at 2-6. On

March 10, 2022, the Office of Federal Operations affirmed the final agency decision because Reid filed his formal complaint outside the 15-day window but did not address whether Reid missed the 45-day filing requirement. Id. The Office of Federal Operations determined Reid failed to provide adequate justification to excuse his untimely filing of the formal complaint, and even though Reid was on military orders during that period, the record showed he had advanced notice of his duty and access to email during the relevant period. Id. at 4. III. District Court Proceedings

Reid, proceeding pro se and in forma pauperis, commenced this action on June 27, 2022 in the United States District Court for the Eastern District of Pennsylvania. ECF Nos. 1-2.

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Bluebook (online)
REID v. VETERANS ADMINISTRATION, PITTSBURGH, PA, Counsel Stack Legal Research, https://law.counselstack.com/opinion/reid-v-veterans-administration-pittsburgh-pa-pawd-2025.