Haynes, T. v. Riverside Presbyterian Apts.

Citation: Not availableDocket: 2896 EDA 2017

Court: Superior Court of Pennsylvania; September 17, 2018; Pennsylvania; State Appellate Court

Original Court Document: View Document

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Twila Haynes appeals a dismissal of her complaint against Riverside Presbyterian Apartments, which was ruled to lack sufficient grounds for relief. The trial court reviewed her in forma pauperis petition alongside her complaint, detailing her employment as a security guard from 2012 to 2014. Haynes alleges she was terminated unjustly and claims her rights were violated under ADA Title I due to her need to wear a surgical mask for a respiratory infection, as recommended by her doctor. Initially permitted to wear the mask, she faced a request for a doctor's note in June 2014, and was subsequently terminated in August 2014. The complaint also notes injuries sustained during her employment but does not clearly establish a causal link between these injuries and the employer's actions. The court found the complaint to be frivolous, leading to this appeal. Haynes contends that the trial court erred by concluding she did not present sufficient factual support for claims of breach of contract, negligence, and ADA violations, emphasizing her medical condition as a recognized disability.

The review of a dismissal under Pa.R.C.P. 240(j) is confined to assessing potential violations of the plaintiff's constitutional rights and determining if the trial court abused its discretion or erred in law. Rule 240 allows individuals without financial means to pursue litigation in forma pauperis. Subsection (j) mandates that a trial court may dismiss a case if the poverty claim is untrue or if the action is deemed frivolous, defined as lacking a legal or factual basis. The trial court found the appellant's complaint frivolous, noting ambiguity in the causes of action cited, including breach of contract, negligence, and a violation of the Americans with Disabilities Act. 

For breach of contract, essential elements must be pleaded, including the existence of a contract and resultant damages; however, no contract was alleged between the appellant and appellee. Regarding negligence, four elements are required: duty, breach, causation, and damages. The complaint suggested injuries during employment but failed to establish a direct link to any duty owed by the appellee. Although a claim under the Workers Compensation Act might have been intended, the court lacks jurisdiction over such claims. Additionally, the complaint was likely barred by the statute of limitations, as it was filed three years after the appellant's termination in 2014, exceeding the two-year limit for personal injury actions under Pennsylvania law.

To establish a prima facie case under the Americans with Disabilities Act (ADA), a plaintiff must show: 1) they are classified as disabled under the ADA; 2) they are qualified to perform the essential job functions, with or without reasonable accommodations; and 3) they have experienced an adverse employment action due to discrimination. In the case of Stultz v. Reese Bros. Inc., 835 A.2d 754 (Pa. Super. 2003), the Complaint did not provide factual allegations to satisfy these criteria. After reviewing the record, including the Appellant's brief and relevant law, the court concluded that the trial court's assessment was valid and that the complaint was frivolous. The court found no constitutional rights violations or abuse of discretion in the trial court's dismissal of the complaint under Rule 240(j)(1). Consequently, the appeal did not warrant relief, and the order to dismiss the complaint was affirmed. Judgment was entered on 9/17/18.