Federal District Court Rules that Prison Business Technology Teacher Did Not Prove Race and Sex Discrimination

Case Name: Felder v. Commonwealth of Pennsylvania Department of Corrections et al

Court: United States District Court – Eastern District of Pennsylvania

Date of Opinion:  February 2nd, 2022

Judge: Pappert

Overview: Prison business technology teacher filed a claim of race and sex discrimination against her workplace.  The judge ruled against her.

Background: Darlea Felder, an African American, worked as a business technology occupational teacher in SCI Graterford, a prison in Pennsylvania.  In June of 2020, Felder sent in an incident report alleging that some of her white colleagues made racist comments. She claims that the remarks were related the protests sparked by George Floyd’s murder.

Her claims were referred to the Equal Employment Opportunity office for the department.  Her supervisor heard about the complaint and was appalled and, at a meeting on June 4th, 2020, recited a policy statement drafted by HR.

In August 2020, the EEO completed its investigation of Felder’s complaints and found that there was no proof of any wrongdoings by her colleagues and that there was not enough evidence that Felder was “racially harassed.”  In April 2021, Felder filed a lawsuit against numerous defendants, claiming race and sex discrimination and retaliation. Felder subsequently withdrew her sex claims, which left her with claims of race discrimination and retaliation.

In order to show race discrimination, the plaintiff must show that a) she belongs to a protected class, b) she was qualified for her position, c) she suffered adverse employment action, and d) that the circumstances gave rise to unlawful discrimination.

The court maintains that she is a member of a protected class and that she was qualified for her position.   Felder argues that she was placed in a dangerous area of the prison and that her white colleagues were not. The court opines that her claim is time barred because her complaint came after the 300 day window.  In addition, the court opines that this placement was not an adverse employment action.

The court also decided that she was denied supplies, which was a part of her discrimination claim.  The court noted that this was just an inconvenient part of the work environment and not an adverse employment action.

Conclusion:  The judge ruled for the defendant in this case.

Steven M. Cohen
Law Librarian | + posts

Steven M. Cohen is a law librarian at a midsize law firm in New York City.  He was the creator of Library Stuff, one of the first library blogs, which lasted over 15 years.  He obtained his MLS from Queens College in 2002.  His passions include legal research, reading novels, and rooting on his favorite sports teams.