Michalene Peticca v. The Roman Catholic Diocese of Harrisburg

Summary

This memorandum addresses the Roman Catholic Diocese of Harrisburg’s motion for summary judgment in Michalene Peticca’s action concerning alleged unpaid overtime, FMLA retaliation, and denial of short-term disability benefits. The court states that it will grant the motion in part and deny it in part. The excerpt includes the factual and procedural background, jurisdiction, summary-judgment standard, and the beginning of the discussion of the FLSA and Pennsylvania Minimum Wage Act claims.

Holdings

1. Summary judgment was inappropriate because genuine disputes of material fact remained concerning whether Peticca's primary duty as cemetery manager was exempt administrative work or nonexempt physical and manual work.
2. Peticca established sufficient evidence of causation to survive summary judgment on her FMLA retaliation claim.
3. The Diocese articulated a legitimate, nondiscriminatory reason for termination, but summary judgment was improper because Peticca presented evidence from which a factfinder could disbelieve that reason and find pretext.
4. Neither the Diocese's employee handbook nor its short-term disability plan created an enforceable unilateral contract, so the Diocese was entitled to summary judgment on the breach-of-contract and WPCL claims.

Questions Presented

1. Whether genuine disputes of material fact precluded summary judgment on whether Peticca's primary duty qualified her for the FLSA and PMWA administrative exemptions from overtime requirements.
2. Whether Peticca presented sufficient evidence to establish causation and pretext for her FMLA retaliation claim.
3. Whether the Diocese's employee handbook or short-term disability plan created an enforceable unilateral contract under Pennsylvania law.
4. Whether Peticca's WPCL claim could survive absent an enforceable contract governing her alleged short-term disability compensation.

Disposition

other