U.S. District Judge Susan Paradise Baxter ruled on April 2, 2026, in Sturgis v. Diamond Hospitality Services, LLC, allowing the core of the employment dispute to proceed to discovery. The case centers on allegations that a hotel manager altered the schedule, issued a written warning, and terminated a night audit employee following his return from cancer treatment.
Sturgis, a senior front desk employee with an unblemished record, was diagnosed with cancer in July 2023 and Asperger's Syndrome in 2004. After being hospitalized for chemotherapy from September 18 to November 3, 2023, he returned to work with a 10-pound lift limit.
Instead of his usual Monday-through-Friday schedule, Sturgis alleges he was continually scheduled to work every weekend. He contends this new schedule was unfavorable given his recent return from cancer treatment and his Asperger's Syndrome, a condition known to the Defendants.
The court held that the schedule change constituted a plausible adverse employment action. Judge Baxter reasoned that expanding a workweek from five days to potentially seven days, including demanding weekend shifts, could not be dismissed as a mere inconvenience.
Sturgis also alleged he received his first written warning in March 2024 for allegedly failing to stock breakfast, a duty he believed was not part of his job. The court found this warning plausible as an adverse action because it operated within a progressive disciplinary framework capable of affecting his employment terms.
Regarding causation, the court rejected the defendants' argument that the four-month gap between Sturgis's return and the warning was too remote to suggest discrimination. The court noted that Sturgis alleged a pattern of antagonism, including the schedule change and subsequent termination for playing computer games on his shift—a practice he claimed had prior permission.
The court denied the motion to dismiss the retaliation claims under the ADA, FMLA, and PHRA. It held that Sturgis plausibly alleged he engaged in protected activity by requesting medical leave and reinstating his schedule, and that a causal link to his termination was sufficiently pleaded at this stage.
However, the court granted dismissal of the hostile work environment claim. Judge Baxter ruled that discrete employment decisions, such as a schedule change and a single written warning, do not amount to the severity or pervasiveness required to create an objectively abusive working environment.
The failure-to-accommodate claim was also dismissed with prejudice. The court found the complaint lacked any factual assertion that Sturgis requested a reasonable accommodation or that the defendants failed to engage in the interactive process.
The tortious interference claim was dismissed without prejudice. The court noted that Sturgis conceded the defendants were joint employers, which would foreclose the claim as a matter of law, though discovery might reveal otherwise.