Theresa Gallagher v. Central Valley School District

CourtCourt of Appeals for the Third Circuit
DecidedMarch 6, 2026
Docket24-2757
StatusUnpublished

This text of Theresa Gallagher v. Central Valley School District (Theresa Gallagher v. Central Valley School District) 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
Theresa Gallagher v. Central Valley School District, (3d Cir. 2026).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT _______________

No. 24-2757 _______________

THERESA A. GALLAGHER, Appellant

v.

CENTRAL VALLEY SCHOOL DISTRICT _______________

On Appeal from the United States District Court for the Western District of Pennsylvania (D.C. No. 2:22-cv-01791) District Judge: Honorable William S. Stickman IV _______________

Submitted Pursuant to Third Circuit L.A.R. 34.1(a) December 1, 2025 _______________

Before: CHAGARES, Chief Judge, FREEMAN and MASCOTT, Circuit Judges.

(Filed: March 6, 2026) _______________

OPINION * _______________

CHAGARES, Chief Judge.

* This disposition is not an opinion of the full Court and, pursuant to 3d Cir. I.O.P. 5.7, does not constitute binding precedent. Theresa Gallagher appeals the District Court’s grant of summary judgment to the

Central Valley School District (“Central Valley”) on her claims of age discrimination

under the Age Discrimination in Employment Act (“ADEA”) and Pennsylvania Human

Relations Act (“PHRA”). For the following reasons, we will affirm.

I. 1

Gallagher is a 52-year-old woman who began working as a substitute teacher for

Central Valley in 2001. Starting in 2013, Gallagher began to indicate to Central Valley

Superintendent Nicholas Perry that she was interested in a permanent teaching position.

She intermittently reiterated this interest throughout the next eight years.

Central Valley learned that it would need to hire a permanent third-grade teacher

at Todd Lane Elementary School in early 2021. Pursuant to section 304.1 of Central

Valley’s Policies and Procedures, Perry had the discretion to fill this position through

either: (1) advertising the open position and conducting a formal application, interview,

and teaching demonstration process; or (2) “modify[ing] this process to meet the needs of

the district.” Appendix (“App.”) 665–66. Given the difficulty of conducting teaching

demonstrations and interviews during the then-ongoing COVID-19 pandemic, Perry

utilized the latter method and approached Christina Feragotti, Todd Lane’s principal, to

ask her if there were any long-term substitutes at the school who might be a good

candidate. Feragotti recommended Casey Reinstadtler — a younger individual — who

had been serving as a long-term third-grade substitute teacher at Todd Lane for the past

1 We write primarily for the parties and so recite only the facts necessary to decide the case.

2 two years. Perry then recommended Reinstadtler to the Central Valley School Board,

which scheduled a vote on whether to hire her. When Gallagher learned of the upcoming

vote, she immediately emailed members of the School Board to express her interest in the

position. Nevertheless, on June 17, 2021, the School Board voted to hire Reinstadtler.

Two months later, on August 5, 2021, Gallagher spoke on the phone with Donna

Belcastro, the president of the Central Valley School Board, who disclosed that Perry was

never going to hire her because “you are too old, Theresa, he is not going to hire anyone

with experience. He wants young kids that he can push around.” App. 287. Belcastro

further provided Gallagher with an example, explaining that Perry had recently rejected a

candidate with 17 years of experience for an open guidance counselor position. Shortly

after that phone call, Perry introduced the newly hired teachers — including Reinstadtler

— at a School Board meeting by stating: “We have 13 new teachers, young fresh faces

excited to get into education.” App. 531.

Claiming “extreme humiliation” as a result of these events, Gallagher sought and

ultimately obtained a permanent teaching position in another school district. App. 695.

She subsequently filed suit against Central Valley, alleging age discrimination in

violation of the ADEA and PHRA. The District Court granted summary judgment to

Central Valley on both claims, finding that Gallagher had failed to establish that Central

Valley’s reasons for hiring Reinstadtler were pretextual. Gallagher timely appealed.

II. 2

2 The District Court had jurisdiction pursuant to 28 U.S.C. §§ 1331, 1343(a) and 1367. We have jurisdiction pursuant to 28 U.S.C. § 1291. We review a grant of summary judgment

3 We evaluate plaintiffs’ claims of age discrimination under the ADEA and PHRA

by following the familiar burden-shifting framework established by the Supreme Court in

McDonell Douglas Corp. v. Green, 411 U.S. 792 (1973). 3 See Willis v. UPMC

Children’s Hosp. of Pittsburgh, 808 F.3d 638, 643–45 (3d Cir. 2015). Because the parties

agree that Gallagher has established a prima facie case of age discrimination and

Gallagher does not challenge the District Court’s finding that Central Valley articulated a

legitimate non-discriminatory reason for hiring Reinstadtler, only the third step — pretext

— is at issue.

A.

1.

Gallagher first contends that the District Court misapplied the summary judgment

standard by analyzing and weighing each proffered instance of pretext individually,

rather than considering them as a whole in the light most favorable to her as the

nonmoving party.

de novo, applying the same standard that the District Court applied. Viera v. Life Ins. Co. of N. Am., 642 F.3d 407, 413 (3d Cir. 2011). Under that standard, summary judgment is warranted where, upon viewing the facts and drawing all reasonable inferences in the light most favorable to the nonmovant, Hugh v. Butler Cnty. Family YMCA, 418 F.3d 265, 267 (2005), “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). 3 This Court has explained “that the PHRA is to be interpreted as identical to federal anti- discrimination laws except where there is something specifically different in its language requiring that it be treated differently.” Fogleman v. Mercy Hosp., Inc., 283 F.3d 561, 567 (3d Cir. 2002). Since no such difference is present here, we apply an identical analysis to both Gallagher’s ADEA and PHRA claims. See Colwell v. Rite Aid Corp., 602 F.3d 495, 499 n.3 (3d Cir. 2010) (noting that it is “proper to address ADEA and PHRA age discrimination claims collectively” (brackets and quotation marks omitted)).

4 We disagree. True, we have previously cautioned that in analyzing discrimination

claims on summary judgment, courts must “view the facts in the light most favorable to

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Related

McDonnell Douglas Corp. v. Green
411 U.S. 792 (Supreme Court, 1973)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Staub v. Proctor Hospital
131 S. Ct. 1186 (Supreme Court, 2011)
Viera v. Life Insurance Co. of North America
642 F.3d 407 (Third Circuit, 2011)
John M. Ryder v. Westinghouse Electric Corporation
128 F.3d 128 (Third Circuit, 1997)
Patricia M. Pivirotto v. Innovative Systems, Inc
191 F.3d 344 (Third Circuit, 1999)
Gregory Fogleman v. Mercy Hospital, Inc
283 F.3d 561 (Third Circuit, 2002)
Cherie Hugh v. Butler County Family Ymca
418 F.3d 265 (Third Circuit, 2005)
Colwell v. Rite Aid Corp.
602 F.3d 495 (Third Circuit, 2010)
Byron Halsey v. Frank Pfeiffer
750 F.3d 273 (Third Circuit, 2014)
Catherine Willis v. Childrens Hospital of Pittsbur
808 F.3d 638 (Third Circuit, 2015)

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Theresa Gallagher v. Central Valley School District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/theresa-gallagher-v-central-valley-school-district-ca3-2026.