Piotrowski v. Signature Collision Ctrs., LLC

Piotrowski v. Signature Collision Ctrs., LLC

Opinion

MEMORANDUM

Like so many people, the Covid-19 pandemic upended Edgar Piotrowski's life. At the outset of the pandemic, his doctor told him not to go to work, and his employer, Signature Collision Centers, LLC, told him not to stay home. Stuck between a rock and a hard place, he chose his health. When Signature fired him, he sued. The Court must now decide what claims can survive, including under the Emergency Paid Sick Leave Act ("EPSLA") that Congress passed in the pandemic's early days. Unfortunately, much about that statute reflects the hurried way in which Congress passed it, and the Court must now pick up the pieces of the statute's imprecise language. As explained below, the Court concludes that Mr. Piotrowski has stated claims against Signature for interference with his rights under the Americans with Disabilities Act and for denial of sick leave under the EPSLA, but he has not stated a plausible claim for retaliation [*2]  under the EPSLA.

I. FACTUAL BACKGROUND

Mr. Piotrowski was the General Manager of Signature's Lansdale location. His job duties included hiring and firing employees, overseeing estimates and repair work, communicating with clients and customers, and inventory sourcing. Mr. Piotrowski was and is an insulin dependent, Type-1 diabetic.

On March 17, 2020, in the first days of Covid-19-related shutdowns, Mr. Piotrowski emailed Signature to explain that his diabetes was a disability and to request and propose accommodations. The next day, Signature informed Mr. Piotrowski that he could use sick days or paid time off ("PTO") to cover his absences. In reply, Mr. Piotrowski reiterated his initial request and included multiple links to government-issued articles that address reasonable accommodations under the ADA in preparation for the pandemic (i.e., working from home and by Telework). Signature then told Mr. Piotrowski he had to be physically present to perform the essential functions of his position and that any additional days not covered by sick or PTO will be unpaid.

On March 19, 2020, Mr. Piotrowski submitted a note from his endocrinologist stating that he is immunosuppressed due to his diabetes [*3]  and should "remain off" for two weeks. (ECF No. 7, ¶ 59.) After additional emails, Mr. Piotrowski spoke by phone with his superior and an HR representative. They told him that his doctor's note did not mention a reasonable accommodation for his disability. So, on March 25, 2020, Mr. Piotrowski provided Signature with a second doctor's note. That note stated, "Due to an increased risk of complications from the Coronavirus, it is recommended that [Mr. Piotrowski] be provided with accommodations to work from at home [sic]." (Id. ¶ 66.) The next day, Signature told Mr. Piotrowski that it would not provide him with additional sick leave because the second doctor's note did not advise him to quarantine. Mr. Piotrowski asked exactly what he needed his doctor's note to say, and Signature agreed to provide him with precise language.

Full case includes Shepard's, Headnotes, Legal Analytics from Lex Machina, and more.