Pa. Human Relations Act Does Not Apply to Judiciary, Supreme Court Rules
The decision affirms rulings from the Commonwealth Court and the trial court, which had dismissed the plaintiff parole officer's discrimination case at the preliminary objections stage.
July 21, 2020 at 05:10 PM
4 minute read
Pennsylvania's highest court has determined that the state's Human Relations Act does not apply to the judiciary or its employees.
The state Supreme Court on Tuesday ruled in Renner v. Court of Common Pleas of Lehigh County that applying the Pennsylvania Human Relations Act to the judiciary would violate the separation of powers doctrine and encroach on the judiciary's ability to select, fire and supervise its own employees. The decision affirms rulings from the Commonwealth Court and the trial court, which had dismissed the plaintiff parole officer's discrimination case at the preliminary objections stage.
Although counsel for the plaintiff, Michael Renner, had told the justices that, when enacting the PHRA, the General Assembly intended to waive immunities for all commonwealth agencies, Justice Debra Todd, who wrote the court's opinion, said allowing the court to be subjected to the act would violate the separation of powers doctrine.
"To apply the PHRA to the judiciary would manifestly interfere with these personnel decisions. We find this to be true whether the PHRA is applied by the executive branch through the PHRC, or by the courts themselves," she said. "Regardless, it is an incursion into our exclusive and independent domain to supervise judiciary personnel."
Todd was joined by all other justices, except for Chief Justice Thomas Saylor, who wrote a concurring opinion.
The case stems from charges Renner filed with both the Equal Employment Opportunity Commission and the Pennsylvania Human Relations Commission alleging unlawful discrimination by the Lehigh County Court of Common Pleas.
According to court documents, Renner alleged he was subjected to a hostile work environment while a Lehigh County parole officer and was eventually fired after taking a medical leave. Renner, court documents said, protested the termination to the Lehigh County court president judge, who was the appeals officer, but the judge refused to take action.
According to court records, Renner then became a police officer, but, he alleged that the court continued to interfere with his employment, including barring him from carrying a gun or taser in the court and providing false and misleading job references. Renner eventually sued the court, as well as county officials, but the trial court dismissed the case at the preliminary objections stage. Renner appealed to the Commonwealth Court, which issued a per curiam order in October 2018 affirming the decision.
Todd initially looked to precedent involving whether the Pennsylvania Human Relations Commission had jurisdiction over the judiciary, and said the case law has been somewhat muddled.
First, Todd looked to a 1983 case that held that the Human Right Commission did not violate the separation of powers in a case involving a common pleas court. However, 10 years later, she noted, in the case Court of Common Pleas of Erie County v. Pennsylvania Human Relations Commission, which involved a probation officer, the court found that the commission would encroach on the court's powers, although it also said it was possible to bring PHRA claims in court, rather than first going through the commission.
According to Todd, this created some confusion, which the court tried to address three years later, ultimately ruling in First Judicial District v. Pennsylvania Human Relations Commission that the commission could not exercise jurisdiction over the courts.
Todd, however, said the high court had not yet fully addressed the question of whether court employees can bypass the commission and instead bring the claims directly to court, which was condoned in Erie County. But ultimately, Todd determined that the suggestion in Erie County that court employees could file PHRA claims in court was dicta, as it was a "one sentence response" to a suggestion by the dissent and "devoid of analysis" was dicta.
After determining that allowing courts to adjudicate PHRA claims would encroach on the court's powers, Todd also said the judiciary is already regulating its employees through the Code of Conduct.
"There is a meaningful avenue of reporting and processing claims of discrimination or harassment under the Code of Conduct with respect to county-level court employees, with the president judge of each judicial district responsible for disseminating and enforcing the Code of Conduct." she said.
Hahalis & Kounoupis attorney David Deratzian, who represented the plaintiff, did not return a call seeking comment.
A spokeswoman at the AOPC declined to comment.
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