Wert v. The Pennsylvania State University

CourtDistrict Court, M.D. Pennsylvania
DecidedApril 15, 2022
Docket4:19-cv-00155
StatusUnknown

This text of Wert v. The Pennsylvania State University (Wert v. The Pennsylvania State University) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wert v. The Pennsylvania State University, (M.D. Pa. 2022).

Opinion

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

BRENDA WERT, No. 4:19-CV-00155

Plaintiff, (Chief Judge Brann)

v.

THE PENNSYLVANIA STATE UNIVERSITY,

Defendant.

MEMORANDUM OPINION APRIL 15, 2022 I. BACKGROUND In June 2016, after over a decade and a half in various other positions at Penn State University, Brenda Wert transitioned into a role as an accountant in the University’s Department of Plant Science.1 But her tenure was short-lived. By October 2016, there were rumbling of Penn State’s discontent, with Wert’s supervisor calling her into a meeting to warn her about her poor attendance.2 And in May 2017, some seven months later, Penn State fired her—citing her continued excessive absenteeism, her repeated failures to properly notify her supervisor that she’d be out, her habitual unapproved adjustments to her work schedule, and her failure to submit her March timesheet on time.3

1 Wert v. Pennsylvania State Univ., 2021 WL 1721574, at *2 (M.D. Pa. Apr. 30, 2021). 2 Id. Wert, however, questions Penn State’s rationale. She believes that her firing stemmed from her use of the Family Medical Leave Act (FMLA). When she began

in the Department of Plant Science, she held a certification allowing her to take a day of FMLA leave per week for migraines.4 But soon after, Penn State asked her for an updated certification—a request occasioned by her use of more days a week than she was allotted.5 In renewing her certification, Wert’s doctor upped her leave,

finding that her migraines required that she take off up to 4 days a week.6 Faced with this increased allotment, Penn State began requiring Wert to submit monthly updates and exercised its right under the FMLA to have a doctor of its choosing evaluate

Wert—and this doctor found that her condition did not warrant FMLA leave at all.7 Second opinion in hand, Penn State denied Wert’s certification and informed her that, as of January 26, 2017 she would no longer be able to take FMLA leave for her migraines.8

After trying to take FMLA leave for a migraine on January 27, 2017—a request that was rejected—Wert made no further attempts, instead logging these days as ordinary sick leave.9 And just four months later, she was let go.10

4 Wert, 2021 WL 1721574, at *3. 5 Id. 6 Id. 7 Id. 8 Id. 9 Doc. 52 at 18. In January 2019, Wert sued Penn State, alleging two violations of the FMLA.11 The case proceeded to summary judgment. And while I dismissed Wert’s

first count, which claimed that Penn State had retaliated against her for invoking her rights under the Act, I allowed her second count, alleging that Penn State had interfered with her rights under the FMLA, to proceed.12 With trial set for May 16,

2022, I now consider Penn State’s motion in limine asking that I prevent Wert from presenting evidence that goes to the heart of her case.13 That motion is fully briefed and ripe for disposition. II. LEGAL STANDARD

The purpose of motions in limine are to aid the clear presentation of evidence at trial. “Evidence should only be excluded on a motion in limine if it is clearly inadmissible on all potential grounds. The movant bears the burden of demonstrating that the evidence is inadmissible . . . .”14

III. ANALYSIS Penn State’s motion in limine makes four arguments, which can be separated into pairs. The first and second center on the requirement that Wert prove damages,

essentially arguing that because I dismissed Wert’s retaliation claim, her firing was therefore legitimate, nondiscriminatory, and valid, thus bringing this case to a close.

11 See generally Doc. 1. 12 Wert, 2021 WL 1721574, at *4–6. 13 See generally Doc. 50; Doc. 51; Doc. 53. The third and fourth focus on the lawfulness of the opinion that Penn State used to deny Wert’s continued leave. The University argues that as result, Wert cannot prove

that it interfered, that she had a serious medical condition, or that she gave notice of her intention to take FMLA leave—any one of which would upend her case. I’ll address each in turn.

A. The Effect of This Court’s Dismissal of Wert’s Retaliation Claim Penn State’s claim that my dismissal of Wert’s retaliation claim prevents her from recovering post-termination losses, and in turn warrants the dismissal of the case, rests on the confluence of two areas of law. First is the law limiting employer’s

liability for post-termination wages after a lawful termination. It is elementary that “[a]n employee who requests FMLA leave [has] no greater protection against his or her employment being terminated for reasons not related to his or her FMLA request than he or she did before submitting that request.”15 And when an “employment

relationship has been terminated for lawful reasons, the employer no longer has a duty to compensate the employee.”16 Indeed, any other rule “would interfere with an employer’s right to hire and fire at will.”17 As a result, an employer’s “[l]iability for

lost wages . . . cease[s] when the employment relationship lawfully ends.”18 Second

15 Bearley v. Friendly Ice Cream Corp., 322 F. Supp. 2d 563, 571 (M.D. Pa. 2004) (Caputo, J.) (quoting Gunnell v. Utah Valley State Coll., 152 F.3d 1253, 1262 (10th Cir. 1998)). 16 Lapham v. Vanguard Cellular Sys., Inc., 102 F. Supp. 2d 266, 270 (M.D. Pa. 2000) (Caldwell, J.). 17 Id. (citing McKennon v. Nashville Banner Publ’g Co., 513 U.S. 352, 361 (1995) and Hite v. Biomet, Inc., 53 F. Supp. 2d 1013, 1026 (N.D. Ind. 1999)). is the law providing that proof of economic loss is a necessary component of an FMLA claim. Even in the face of blatant violations, without this showing, an

employee’s claim must be dismissed.19 There’s an intuitive appeal to Penn State’s argument: if a reasonable jury could not conclude that Wert had overcome Penn State’s clear nondiscriminatory

rationale for firing her—to say nothing of showing a causal connection between her leave and her firing at the first stage of the McDonnell Douglas framework—how could they find that Penn State’s interference with her FMLA rights caused her firing? But this syllogism irons over essential distinctions; under the FMLA,

“retaliation is not the only impermissible reason for dismissal.”20 29 U.S.C. § 2615 provides plaintiffs two causes of action: section 2615(a)(1), prohibits employers from interfering with employees “exercise” or “attempt[s] to exercise” their leave rights;21 while section 2615(a)(2) prohibits employers from

retaliating against an employee for invoking their right to FMLA leave.22 But neither interference nor retaliation alone sustains a claim. Plaintiffs must also prove that the

19 Id. at 270 (citing Kelly N. Honohan, Note, Remedying the Liability Limitation under the Family and Medical Leave Act, 73 B.U. L. Rev. 1043, 1049 (1999)). 20 Smith v. Diffee Ford-Lincoln-Mercury, Inc., 298 F.3d 955, 961 (10th Cir. 2002). 21 29 U.S.C. § 2615(a)(1) (“It shall be unlawful for any employer to interfere with, restrain, or deny the exercise of or the attempt to exercise, any right provided under this subchapter.”). 22 29 U.S.C.

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