3rd Circuit affirms summary judgment in racial bias and retaliation case

A panel from the U.S. 3rd Circuit Court of Appeals has upheld a ruling that a white Philadelphia police officer didn’t make a case for discrimination or retaliation following his termination from the Philadelphia Housing Authority (PHA).

The officer, John Morozin, filed a suit against the PHA, PHA’s Executive Vice President of HR Joanne Strauss, and PHA’s Chief of Police Branville Bard, alleging his termination was because of his race and was in retaliation for complaints he made about not receiving adequate overtime pay. The case serves a reminder for employers about the importance of keeping adequate documentation surrounding employee termination, which could prove to be the difference between being successful at the summary judgment stage versus going to trial.

Facts

John Morozin worked for PHA’s police department from 2013 until his termination in 2016. He was initially hired as a patrol officer but was promoted to a lieutenant in 2015. Before his termination, he filed a series of complaints about his pay to Bard, Strauss, and other HR employees claiming that he wasn’t receiving overtime wages.

In May 2016, Morozin stated he would take his complaints to the PHA if his issues weren’t addressed. On June 5, 2016, he followed up again, and his issues were resolved by June 10, 2016. During this time, other employees also complained about mistakes regarding payroll at PHA.