THOMAS v. SHEET METAL WORKERS LOCAL UNION 19

CourtDistrict Court, E.D. Pennsylvania
DecidedAugust 6, 2025
Docket5:24-cv-01399
StatusUnknown

This text of THOMAS v. SHEET METAL WORKERS LOCAL UNION 19 (THOMAS v. SHEET METAL WORKERS LOCAL UNION 19) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
THOMAS v. SHEET METAL WORKERS LOCAL UNION 19, (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

ALEXA THOMAS Plaintiff Civil No. 24-1399

v.

SHEET METAL WORKERS LOCAL UNION 19 et al. Defendants

MEMORANDUM Costello, J. August 6, 2025 Plaintiff Alexa Thomas has sued Defendants Sheet Metal Workers’ Joint Apprenticeship Training Fund of Central Pennsylvania (“Joint Apprenticeship Fund”) and Sheet Metal Workers Local Union 19 (“Union”) for discriminating against her because of her gender and disability while she was working as a sheet metal apprentice. Thomas claims that Defendants violated Title VII of the Civil Rights Act of 1964 (“Title VII”), the Americans with Disabilities Act (“ADA”), and the Pennsylvania Human Relations Act (“PHRA”). Defendants have moved to dismiss all of Thomas’s claims. For the reasons that follow, the Court will grant Defendants’ motions in part and deny them in part. I. BACKGROUND Thomas claims she was employed as a sheet metal apprentice for the Joint Apprenticeship Fund and the Union from May 8, 2020 until September 7, 2022, when her apprenticeship was terminated. ECF No. 1 at ¶ 13. Thomas alleges that she experienced serious health conditions during her apprenticeship. Id. ¶ 33. Defendants reportedly reacted to her conditions with hostility, warning her that she would be laid off if she missed work for medical reasons. Id. ¶¶ 33-34. In addition, Thomas alleges that she was subjected to sexual harassment and sexual assault. Id. ¶¶ 36-39. Thomas claims that she reported her mistreatment to Defendants. Id. ¶¶ 37-42. In response, Defendants purportedly terminated Thomas’s apprenticeship for willful misconduct for not being present for all required hours. Id. ¶ 48.

Thomas, however, alleges that Defendants terminated her apprenticeship because she reported the discrimination she experienced. Id. ¶¶ 55-57, 64-65, 71-73, 80-81. Both the Joint Apprenticeship Fund and the Union moved to dismiss Thomas’s claims. See ECF No. 12; ECF No. 14. First, both Defendants argue that Thomas’s PHRA, Title VII, and ADA claims should be dismissed because Thomas failed to exhaust her administrative remedies. Second, both Defendants argue that Thomas’s claims should be dismissed because Thomas failed to allege facts showing they were her employers. Third, both Defendants argue that Thomas’s true employers were third-party contractors that Thomas worked with as an apprentice and that Thomas’s claims should be dismissed because she failed to join them in this lawsuit. II. LEGAL STANDARDS

A. Rule 12(b)(6) A court can dismiss a plaintiff’s complaint under Federal Rule of Civil Procedure 12(b)(6) if the plaintiff “fail[ed] to state a claim upon which relief can be granted.” Fed R. Civ. P. 12(b)(6). When reviewing a Rule 12(b)(6) motion, the Court should “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.” See Phillips v. Cnty. of Allegheny, 515 F.3d 224, 233 (3d Cir. 2008) (quotation omitted). When reviewing a Rule 12(b)(6) motion, the Court should consider the complaint and may also consider “an undisputedly authentic document that a defendant attaches as an exhibit to a motion to dismiss if the plaintiff’s claims are based on the document.” See Pension Benefit Guar. Corp. v. White Consol. Indus., Inc., 998 F.2d 1192, 1196 (3d Cir. 1993). Additionally, the

Court can consider “matters of public record.” See Rogan v. Giant Eagle, Inc., 113 F. Supp. 2d 777, 780 (W.D. Pa. 2000), aff’d 276 F.3d 579 (3d Cir. 2001). For example, the Court may consider documents like Equal Employment Opportunity Commission (“EEOC”) charges and other documents related to EEOC investigations as public records or as documents that are relied upon or integral to a complaint. See Rogan, 113 F. Supp. 2d at 782 (considering EEOC charge and related EEOC documents when resolving a motion to dismiss). The Court may also consider similar documents from state agencies like the Pennsylvania Human Relations Commission (“PHRC”). See Paytas v. Kindred Hosp.-Pittsburgh-North Shore, LLC, Civil Action No. 14-274, 2014 WL 1683276, at *2 (W.D. Pa. Apr. 29, 2014). B. Rule 12(b)(7)

Dismissal is proper under Federal Rule of Civil Procedure 12(b)(7) if the plaintiff “fail[ed] to join a party under Rule 19.” See Fed. R. Civ. P. 12(b)(7). When reviewing a Rule 12(b)(7) motion, the Court must accept the “allegations in the complaint as true and draw all reasonable inferences . . . in favor of the non-moving party.” See Pittsburgh Logistic Sys., Inc. v. C.R. Eng., Inc., 669 F. Supp. 2d 613, 618 (W.D. Pa. 2009). However, the Court may also “consider evidence outside the pleadings.” See id. The moving party has the burden of showing that plaintiff failed to join a party under Rule 19. See id. III. DISCUSSION A. 12(b)(6) – Administrative Exhaustion Under the PHRA Defendants argue that the Court should dismiss Thomas’s PHRA claims because Thomas failed to cooperate with the PHRC’s investigation and therefore has failed to exhaust her administrative remedies.1 See ECF No. 12 at 12-16; ECF No. 14 at 15-18. To exhaust claims

brought under the PHRA, a plaintiff must file a complaint with the PHRC and give the PHRC one year to investigate. See Burgh v. Borough Council of Borough of Montrose, 251 F.3d 465, 471 (3d Cir. 2001). If the PHRC has not resolved the complaint after one year, the plaintiff has

1 Thomas responds in part that the Court should not consider exhaustion arguments raised in a Rule 12(b)(6) motion. See ECF No. 17 at 7-9; ECF No. 18 at 7-9. However, the Court can consider exhaustion arguments raised in a 12(b)(6) motion where it is clear from the “face of the complaint” and documents properly considered that a plaintiff has failed to exhaust her administrative remedies, including where the failure to exhaust arises from a plaintiff’s failure to cooperate with an administrative investigation. See Jones v. De. River Stevedores, Inc., Civ. Action No. 18-4276, 2019 WL 498517, at *3 (E.D. Pa. Feb. 7, 2019) (granting motion to dismiss PHRA claim for failure to exhaust because one-year investigation period had not expired); Ellis v. Mohenis Servs., Inc., No. Civ. A. 96-6307, 1997 WL 364468, at *3 (E.D. Pa. June 18, 1997) (observing—while finding that plaintiff’s ADA claim survived a motion to dismiss for failure to exhaust—that plaintiff had failed to “invoke” the PHRA because “Plaintiff’s attorney . . . sent a letter requesting that the PHRC not go forward with its investigation”); see also Wood v. Cent. Parking Sys. of Pa., Inc., No. Civ. A. 99-3022, 2000 WL 873310, at *3-4 (E.D. Pa. June 23, 2000) (granting motion to dismiss for failure to exhaust EEOC remedies where the EEOC dismissed plaintiff’s charge “for failing to cooperate with its investigation”); Kozlowski v. Extendicare Health Servs., Inc., No. 99-4338, 2000 WL 193502, at *2 (E.D. Pa. Feb.

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THOMAS v. SHEET METAL WORKERS LOCAL UNION 19, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thomas-v-sheet-metal-workers-local-union-19-paed-2025.