Complaint Against Saunders Nursing and Rehabilitation Center , Filed by Tyronda Forrest. (Attachments: # 1 Civil Cover Sheet, # 2 Designation Form)(Schreiber, Andrew)
1Plaintiff brings this action to redress violations by the Defendant of the Americans with Disabilities Act (“ADA”), 42 U.S.C. § 12101, et seq. and the Pennsylvania Human Relations Act (“PHRA”), 43 P.S. § 951, et seq. As a result, Plaintiff has suffered damages set forth herein.
PARTIES
2Plaintiff Tyronda Forrest is a citizen of the United States and Pennsylvania, and currently maintains a residence at 2904 W. 6th Street, Chester, Pennsylvania, 19103.
3Defendant Saunders Nursing and Rehabilitation Center is a for-profit corporation registered to do business in the Commonwealth of Pennsylvania and maintains a place of business located at 100 Lancaster Avenue, Penn Wynne, Pennsylvania 19096.
JURISDICTION AND VENUE
4On or around August 6, 2025, Plaintiff filed a Charge of Discrimination with the United States Equal Employment Opportunity Commission (“EEOC”), which was dually filed with the Pennsylvania Human Relations Commission (“PHRC”), thereby satisfying the requirements of 42 U.S.C. § 2000e5(b) and (e), and 43 P.S. § 959(a). Plaintiff’s EEOC Charge was docketed as EEOC Charge No. 530-2025-08760. Plaintiff’s EEOC Charge was filed within one hundred and eighty (180) days of the unlawful employment practice.
5By correspondence dated February 3, 2026, Plaintiff received a Notice of Right to Sue from the EEOC with respect to her Charge, advising that Plaintiff had ninety (90) days to file suit against Defendant.
6Plaintiff filed the instant action within the statutory time frame applicable to her claims.
7Plaintiff has therefore exhausted her administrative remedies and has complied with all conditions precedent to maintain this action.
8This is an action authorized and instituted pursuant to the Americans with Disabilities Act (“ADA”), 42 U.S.C. § 12101, et seq. and the Pennsylvania Human Relation Act (“PHRA”), 43 P.S. § 951, et seq.
9This Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 1331 and 1343, as it is a civil rights action arising under the laws of the United States.
10This Court has pendant jurisdiction over Plaintiff’s state law claim pursuant to 28 U.S.C. § 1367, as those claims arise out of the same common nucleus of operative fact as her federal claims.
11Venue in this district is proper pursuant to 28 U.S.C. § 1391(b), as the parties reside in this judicial district, doing business therein, and the unlawful practices of which Plaintiff is complaining were committed in this district.
FACTS
12Paragraphs 1 through 11 are hereby incorporated by reference as though the same were fully set forth at length herein.
13On or around June 11, 2012, Defendant hired Plaintiff in the position of Housekeeper.
14At all times material hereto, Plaintiff performed her job well, received positive reviews, praise, and was subjected to no justifiable discipline.
15On or about February 6, 2024, Plaintiff sustained an injury to her right hand and knee.
16Plaintiff’s right hand and knee necessitated surgery.
17Plaintiff’s right hand and knee and the effects thereafter constituted a disability within the meaning of the ADA and PHRA in that they substantially impaired one or more of Plaintiff’s major life activities.
18Plaintiff underwent surgery.
19Following surgery, Plaintiff returned to work in a light duty capacity per her doctor’s request/orders.
20However, Defendant took issue with Plaintiff requesting and working in a light duty capacity.
21Defendant wanted Plaintiff to return to a full duty position, despite the fact that Plaintiff was not yet cleared by her doctor to work in a full duty capacity.
22Indeed, in or around November 2024, Plaintiff received a letter from Defendant stating that Plaintiff must return to work in a full duty capacity by December 20, 2024.
23However, per Plaintiff’s doctors orders, Plaintiff had a return to work date in a full duty capacity of on or about February 20, 2025.
24Plaintiff made the aforementioned request for accommodation with Defendant.
25More specifically, Plaintiff’s doctor prepared paperwork regarding the aforementioned accommodation request confirming Plaintiff’s return to work date, which Plaintiff provided to her Supervisor.
26To be sure that Defendant was fully aware of Plaintiff’s request for accommodation/her doctor’s orders, Plaintiff contained Defendant on numerous occasions.
27Plaintiff contained Defendant’s Human Resources via email and phone calls, but did not receive a response.
28Plaintiff also contacted her Union Representative in an attempt to amicably resolve any matters.
29Despite Plaintiff’s multiple efforts, Defendant was unresponsive.
30Thus, Defendant did not engage in the interactive process with Plaintiff to discuss Plaintiff’s requested accommodation.
31No one from Defendant confirmed they had received Plaintiff’s submitted requested accommodation or doctors notes, nor did anyone return Plaintiff’s emails or phone calls.
32Plaintiff was left in the dark, with her attempts to engage in the interactive process blankly ignored.
33Ultimately, on or about February 6, 2025, Defendant terminated Plaintiff from her employment.
34It is believed and therefore averred that Defendant discriminated against Plaintiff because of her actual and/or perceived disabilities, by failing to engage in the interactive process, by failing to accommodate Plaintiff’s requests for reasonable accommodation, and/or in retaliation for Plaintiff’s requests for reasonable accommodation in connection thereto, in violation of the ADA and PHRA.
35As a result of Defendant’s deliberate, willful, malicious, and unlawful actions, Plaintiff has suffered damages, including, but not limited to, loss of employment, promotions, benefits, earnings and earnings potential, loss of potential benefits, and other economic damages, and has also suffered mental anguish, emotional pain and suffering, and emotional distress.
COUNT I AMERICANS WITH DISABILITIES ACT 42 U.S.C. § 12101, et seq. DISCRIMINATION & RETALIATION
36Paragraphs 1 through 34 are hereby incorporated by reference as though the same were fully set forth at length herein.
37At all times relevant hereto, Plaintiff was an employee of Defendant within the meaning of the Americans with Disabilities Act (“ADA”), 42 U.S.C. § 12101, et seq.
38Pursuant to the ADA, Plaintiff is a qualified individual with one or more disabilities.
39Plaintiff suffers from one or more disability within the meaning of the ADA in that it substantially impairs one or more major life activities.
40Despite his disability, Plaintiff was able to perform the essential functions of her job with or without a reasonable accommodation.
41Plaintiff made multiple good-faith requests for reasonable accommodation, per her doctor’s orders.
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Public U.S. federal court record (district court docket 73112441, document 1). Source via the RECAP Archive (Free Law Project). The same record is available from PACER. Informational only — not legal advice.