Darnell Alston v. Pittsburgh Regional Transit, formerly known as Port Authority of Allegheny County

Summary

The United States District Court for the Western District of Pennsylvania overruled Darnell Alston’s objections to a magistrate judge’s Report and Recommendation and adopted the recommendation to dismiss the amended complaint. The court held that Alston failed to plausibly allege that she had been hired for or was entitled to reinstatement to the Bus Driver Recruiter position, that she engaged in protected FMLA-related opposition, or that her termination was causally related to FMLA leave or related complaints. The court granted the defendant’s motion to dismiss and dismissed Counts I and II with prejudice under Federal Rule of Civil Procedure 12(b)(6).

Holdings

1. The amended complaint failed to state an FMLA interference claim because Plaintiff did not allege that she had been hired into the Bus Driver Recruiter position before taking FMLA leave and therefore did not plausibly allege that Defendant failed to restore her to that position or an equivalent position.
2. The amended complaint failed to plausibly allege FMLA retaliation because it did not allege a pattern of retaliatory conduct tied to FMLA leave or a specific FMLA-related complaint, and it did not sufficiently allege a causal connection between Plaintiff's FMLA leave or complaints and her termination.
3. The court could consider Plaintiff's undisputed EEOC charge and related EEOC documents on the Rule 12(b)(6) motion without converting the motion into one for summary judgment because Plaintiff relied on the charge in the complaint and objections, and the documents were referenced in the complaint, central to her claims, or matters of public record.
4. Leave to amend was properly denied because further amendment would be futile.

Questions Presented

1. Whether the amended complaint plausibly alleged an FMLA interference claim based on failure to restore Plaintiff to the Bus Driver Recruiter position.
2. Whether the amended complaint plausibly alleged that Plaintiff's termination was causally related to her use of FMLA leave or complaints concerning the position.
3. Whether the court could consider Plaintiff's undisputed EEOC charge and related documents on a Rule 12(b)(6) motion without converting the motion to one for summary judgment.
4. Whether Plaintiff should be granted leave to amend her complaint.

Disposition

dismissed