Summary
The United States District Court for the Western District of Pennsylvania considers Defendant Dive North Hills, LLC’s motion for summary judgment in Brittany Etkins’s pregnancy-discrimination, retaliation, and accommodation claims under Title VII, the Pennsylvania Human Relations Act, and the Pregnant Workers Fairness Act. The court denies summary judgment on the Title VII and PHRA pregnancy-discrimination claims, finding a genuine dispute regarding pretext and causation. The court grants summary judgment on the Title VII and PHRA retaliation claims and the PWFA claims because the plaintiff did not sufficiently show that she engaged in protected activity or communicated a need for pregnancy-related accommodations.
Holdings
- The evidence was sufficient for a reasonable jury to find a causal nexus between Etkins's pregnancy and termination and to find that the employer's stated reason for termination was pretextual; summary judgment was therefore denied on the pregnancy-discrimination claims.
- Etkins failed to produce evidence that she engaged in protected activity before her termination; the court therefore granted summary judgment on her Title VII and PHRA retaliation claims.
- The court granted summary judgment on Etkins's PWFA failure-to-accommodate, discrimination, and retaliation claims because she did not produce evidence that she communicated a pregnancy-related known limitation or requested pregnancy-related accommodations.
Questions Presented
- Whether Etkins presented sufficient evidence of a causal nexus between her pregnancy and termination, and sufficient evidence of pretext, to avoid summary judgment on her Title VII and PHRA pregnancy-discrimination claims.
- Whether Etkins engaged in protected activity sufficient to support Title VII and PHRA retaliation claims.
- Whether Etkins communicated a pregnancy-related known limitation or requested a reasonable accommodation sufficient to support claims under the Pregnant Workers Fairness Act.
Disposition
other
Cases Cited (37)
- Razak v. Uber Technologies, Inc., 951 F.3d 137, 144 (3d Cir. 2020)(followed)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 255 (1986)(followed)
- NAACP v. North Hudson Regional Fire & Rescue, 665 F.3d 464, 475 (3d Cir. 2011)(followed)
- Matsushita Electric Industrial Co. v. Zenith Radio Corp., 475 U.S. 574, 586-87 (1986)(followed)
- Aman v. Cort Furniture Rental Corp., 85 F.3d 1074, 1080 (3d Cir. 1996)(followed)
- Kaucher v. County of Bucks, 455 F.3d 418, 423 (3d Cir. 2006)(followed)
- Wetzel v. Tucker, 139 F.3d 380, 383 n.2 (3d Cir. 1998)(followed)
- Celotex Corp. v. Catrett, 477 U.S. 317, 322-24 (1986)(followed)
- Burton v. Teleflex Inc., 707 F.3d 417, 425-27 (3d Cir. 2013)(followed)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802-03 (1973)(followed)
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