Timothy McLaughlin v. International Brotherhood of Teamsters Local 249

Court of Appeals for the Third Circuit·Decided August 10, 2026·No. 25-1613·Unpublished

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT

No. 25-1613

TIMOTHY MCLAUGHLIN,

Appellant

v.

THE INTERNATIONAL BROTHERHOOD OF TEAMSTERS LOCAL 249; MARC SCOTT; KATIE SCOTT; BYRON ROLAND; DON KRAUS; MICHAEL A. CEOFFE; FRANK CONFORTI; JOSEPH ROSSI; CBS STUDIOS, INC.; TRISTAR PICTURES, INC.

On Appeal from the United States District Court for the Western District of Pennsylvania (D.C. No. 2:21-cv-00832)

District Judge: Honorable William S. Stickman, IV

Submitted Under Third Circuit L.A.R. 34.1(a)

May 15, 2026

Before: SHWARTZ, MASCOTT, and McKEE, Circuit Judges

(Opinion filed: August 10, 2026)

OPINION

McKEE, Circuit Judge.

 This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent.

Timothy McLaughlin appeals three District Court orders denying his claims that

his blacklisting from work as a driver on movie and television productions violated the

Labor-Management Reporting and Disclosure Act (“LMRDA”), National Labor

Relations Act (“NLRA”), Age Discrimination in Employment Act (“ADEA”), and

Pennsylvania Human Relations Act (“PHRA”).1

McLaughlin’s arguments on appeal rest on the assertions that (1) the International

Brotherhood of Teamsters, Local 249 (“the Union”) has some authority to dictate who

the production companies hire for driver positions,2 and (2) that his age compared to the

average age of drivers selected suggests age-related animus. However, the record shows

that the Union has no authority in the production companies’ decision-making process

and merely comparing McLaughlin’s age to the average age of the selected drivers

ignores the many qualified individuals, forty or older, who were chosen to fill those

positions. Additionally, McLaughlin’s arguments fail because his Amended Complaint

1 McLaughlin’s Amended Complaint contains twelve counts, the following nine of which are at issue in this appeal: Count I – LMRDA Retaliation (Against the Union); Count IV – ADEA Retaliation (Against CBS); Count V – ADEA Retaliation (Against TriStar); Count VI – ADEA Age Discrimination (Against TriStar); Count VII – ADEA Retaliation (Against the Union); Count VIII – ADEA Age Discrimination (Against the Union); Count IX – PHRA Retaliation (Against the Union); Count X – PHRA Age Discrimination (Against the Union); and Count XI – NLRA Breach of Duty of Fair Representation (Against the Union). 2 The standard collective bargaining agreement between the Union and production companies provided that the producers retain “the sole and exclusive right to hire whoever they decide and to reject any member or applicant referred by the Union.” McLaughlin v. Int’l Bhd. of Teamsters, Loc. 249, No. 2:21-CV-832, 2024 WL 4827573, at *13 (W.D. Pa. Nov. 19, 2024). The Application for Referral, which McLaughlin completed for the Union to forward to production companies, states in boldface, capitalized font “LOCAL 249 DOES NOT HAVE ANY RESPONSIBILITY FOR HIRING DECISIONS BY THE PRODUCER.” Appx. 1115 (emphasis in original).

lacks allegations supporting an inference of discriminatory or retaliatory conduct by the

producers or the Union.

For the reasons that follow, we will affirm the District Court.3

I. CBS’s Motion to Dismiss and TriStar’s Motion to Dismiss in Part4 In dismissing McLaughlin’s claims of ADEA age retaliation against CBS Studios

Inc. and TriStar Pictures Inc., the District Court held that “McLaughlin failed to

demonstrate a causal connection between his protected activity and [the producers’]

failure to hire him as a movie driver for [their respective productions].”5 We agree.

We apply McDonnell Douglas Corp. v. Green’s6 burden-shifting framework

where, as here, there is no direct evidence of retaliation.7 Under this framework, “[a]

prima facie case of illegal retaliation requires a showing of ‘(1) protected employee

activity; (2) adverse action by the employer either after or contemporaneous with the

employee’s protected activity; and (3) a causal connection between the employee’s

3 The District Court had jurisdiction under 28 U.S.C. §§ 1331 and 1367(a). We have jurisdiction to review a final order of the District Court under 28 U.S.C. § 1291. 4 We exercise plenary review over the District Court’s dismissal of McLaughlin’s claims. See Fowler v. UPMC Shadyside, 578 F.3d 203, 206 (3d Cir. 2009). Dismissal is appropriate “if, accepting all well-pleaded allegations in the complaint as true and viewing them in the light most favorable to the plaintiff, a court finds that [the] plaintiff’s claims lack facial plausibility.” Warren Gen. Hosp. v. Amgen Inc., 643 F.3d 77, 84 (3d Cir. 2011). 5 McLaughlin v. Int’l Bhd. of Teamsters, Loc. 249, 641 F. Supp. 3d 177, 208–10 (W.D. Pa. 2022). McLaughlin’s claim of ADEA age discrimination against TriStar, discussed in Part II, survived the motion to dismiss. Id. at 211. 6 411 U.S. 792, 802–03 (1973). 7 Daniels v. Sch. Dist. of Phila., 776 F.3d 181, 193 (3d Cir. 2015).

protected activity and the employer’s adverse action.’”8 McLaughlin did not sufficiently

allege the third element, which requires that (1) “the temporal proximity between [his

protected activity and the employers’ adverse action is] unusually suggestive,” or (2)

“any intervening antagonism by the employer, inconsistencies in the reasons the

employer gives for its adverse action, and any other evidence suggest[] that the

employer had a retaliatory animus when taking the adverse action.”9 Two and three

years passed between McLaughlin’s latest protected activity and his failure to be hired

by TriStar and CBS, respectively. While “there is no bright line rule as to what

constitutes unduly suggestive temporal proximity,” we have declined to find an

inference of causation without additional evidence for gaps of far less time between a

protected activity and adverse employment action.10

McLaughlin argues that “[b]ecause it determined that Roland[, CBS’s agent who

failed to hire McLaughlin on the CBS production,] could be liable for [his]

8 EEOC v. Allstate Ins. Co., 778 F.3d 444, 449 (3d Cir. 2015) (quoting Fogleman v. Mercy Hosp., Inc., 283 F.3d 561, 567–68 (3d Cir. 2002)). 9 Daniels, 776 F.3d at 196 (citation modified); McLaughlin sufficiently alleged the first two elements by pleading that CBS’s and TriStar’s respective agents knew that McLaughlin had complained and failed to hire McLaughlin as a movie driver. See McLaughlin, 641 F. Supp. at 207, 210 (concluding that McLaughlin “sufficiently pleaded that” (1) “Roland served as CBS’s agent on One Dollar and that he acted within the scope of his employment when he hired, or failed to hire, movie drivers” and (2) “Kraus and Conforti were TriStar’s agents/employees on the production of A Beautiful Day and, thus, that TriStar could be responsible for their failure to hire McLaughlin as a movie driver”). 10 LeBoon v. Lancaster Jewish Cmty. Ctr. Ass’n, 503 F.3d 217, 233 (3d Cir. 2007) (rejecting a three-month gap); see, e.g., Daniels, 776 F.3d at 198 (rejecting a ten-month gap); Andreoli v. Gates, 482 F.3d 641, 650 (3d Cir. 2007) (rejecting a five-month gap), overruled on other grounds by Castleberry v. STI Grp., 863 F.3d 259, 264 (3d Cir. 2017).

discrimination claims,” the District Court erred in dismissing his claims against CBS.11

McLaughlin argues that the Amended Complaint supported the inference that the CBS

production One Dollar was Roland’s first opportunity to retaliate against him.12

However, drawing all reasonable inferences in favor of McLaughlin,13 the allegations in

the Amended Complaint show that Roland had other earlier opportunities to retaliate

against McLaughlin before One Dollar.14

Thus, we will affirm the grant of dismissal regarding McLaughlin’s ADEA

retaliation claims against CBS and TriStar.

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