IN THE UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF OHIO

EASTERN DIVISION

Susan Pisano

244 Carreg Cain Drive

Granville, Ohio 43023

Plaintiff,

v.

Trinity Health Corporation 

c/o CT Corporation System

4400 Easton Commons Way, Ste. 125 

Columbus, Ohio 43219

-andMount Carmel Health System 

c/o CT Corporation System

4400 Easton Commons Way, Ste. 125 

Columbus, Ohio 43219

Defendants.

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Case No. 2:17-cv-1038

Judge 

Magistrate Judge 

JURY DEMAND ENDORSED HEREON

COMPLAINT

Now comes Plaintiff Susan Pisano (“Plaintiff”) for her complaint against Trinity Health 

Corporation (“Defendant THC” or “THC”) and Mount Carmel Health System (“Defendant 

MCHS” or “MCHS”) (collectively, “Defendants”) hereby states as follows:

I. JURISDICTION AND VENUE

1. The jurisdiction of this Court is invoked pursuant to 28 U.S.C. § 1331 for violations of the 

Family and Medical Leave Act (“FMLA”), 29 U.S.C. § 2601, et seq., and disability discrimination 

in violation of 42 U.S.C. § 12112, et seq., of Title I of the Americans with Disabilities Act of 1990 

(“ADA”), as amended (“ADAAA”). Plaintiff also claims of disability discrimination in violation 

of Ohio Revised Code Chapter 4112 (“Chapter 4112”). Plaintiff brings this action to obtain relief 

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provided in the FMLA, the ADA and ADAAA, and Chapter 4112 as a result of Defendants’

discriminatory and retaliatory conduct towards her resulting in loss of wages, compensation, and 

benefits.

2. This Court’s jurisdiction in this matter is also predicated upon 28 U.S.C. §1367 as this 

Complaint raises additional claims pursuant to the laws of Ohio, over which this Court maintains 

supplemental subject matter jurisdiction because Plaintiff’s state law claims are so related to the 

federal claims that they share a common core of operative facts.

3. Venue is proper in this forum pursuant to 28 U.S.C. §1391, because the Plaintiff entered 

into an employment relationship with Defendants in the Southern District of Ohio, a substantial 

part of the events or omission giving rise to the claim occurred in the Southern District of Ohio,

and Defendants have their principal place of business as well as conducted substantial business in 

the Southern District of Ohio. 

II. PARTIES 

4. Plaintiff Susan Pisano is an individual and resident of Granville in Licking County, Ohio. 

Plaintiff brings this action to redress injuries committed against her as a result of Defendants’

actions.

5. At all times relevant herein, Plaintiff was an “eligible employee” as defined in the FMLA 

in that she was employed by Defendants for at least twelve (12) months and for at least 1,250 

hours of service during the twelve (12) months before she sought FMLA leave from Defendants. 

6. In addition, Plaintiff was an “employee” within the meaning of the ADA and Ohio Revised 

Code § 4112.01(A)(3).

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7. Defendant Trinity Health Corporation (“Defendant THC” or “THC”) is a foreign non-profit 

corporation established and organized under the laws of Indiana, but licensed to conduct 

substantial business in the Southern District of Ohio.

8. Defendant Mount Carmel Health System (“Defendant MCHS” or “MCHS”) is a domestic 

non-profit corporation that conducts substantial business in the Southern District of Ohio. 

9. At all times material herein, Defendants Trinity Health Corporation and Mount Carmel 

Health System (collectively, “Defendants”) were Plaintiff’s “employer” as defined by the FMLA, 

29 U.S.C. § 2611, et seq., the ADA, 42 U.S.C. § 12111(5), and Ohio Revised Code § 

4112.01(A)(2).

III. STATEMENT OF FACTS

10. Plaintiff began her employment with Defendants as a part-time phlebotomist in 2000 and 

was thereafter hired on a full-time basis in that position in 2002. 

11. During her employment with Defendants, Plaintiff consistently met or exceeded her

superiors’ expectations and was qualified to work with reasonable accommodations.

12. Plaintiff has a record of and suffers from the following health condition: a total inability to 

hear due to complete deafness in both ears. Plaintiff’s deafness constitutes a physical impairment 

and a disability and will hereafter be called her “disability.”

13. Plaintiff’s disability substantially limits her major life activities, including but not limited 

to her ability to communicate in-person and by telephone, to hear sounds of all types, and to 

generally interact and communicate verbally as non-deaf individuals. 

14. Plaintiff was qualified and able to perform the essential functions of her phlebotomist 

position with reasonable accommodations despite her deafness and effectively performed the 

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same throughout her employment with Defendants over her approximately fourteen (14) years’ 

of full-time employment with the company. 

15. When Plaintiff began her employment with Defendants, she requested a “Text Telephone” 

device (“TTY”) that would have allowed her to communicate with individuals outside of her 

office despite her disability. 

16. However, Defendants refused to provide Plaintiff with the requested TTY device. 

17. On other occasions, Defendants failed and/or refused to provide Plaintiff with other 

reasonable accommodations she requested.

18. For example, Plaintiff requested but was denied written program materials that would have 

allowed her to fully participate in various employment training programs that other non-deaf 

employees were able to attend and participate in. 

19. When Plaintiff inquired why her requested accommodations had not been provided, 

Defendants simply told her that she should not attend the employee training programs because no 

accommodations would be provided. 

20. Over the years, Defendants additionally failed to provide Plaintiff with other 

accommodations, including interpreters or interpretation services, despite Plaintiff’s repeated 

requests for such services and her obvious need for the same due to her complete deafness. 

21. In or around June of 2016 through August 2016, Plaintiff was placed on continuous FMLA 

medical leave due to severe vertigo caused by an inner ear condition. 

22. On or around September 1, 2016, Plaintiff returned to work following her FMLAqualifying medical leave. 

23. Then, on September 30, 2016, Defendants advised Plaintiff that her position was 

purportedly being eliminated. 

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24. At that same time, Defendants’ human resources representative stated that she had already 

reviewed all of Defendants’ available job postings and there were no openings for Plaintiff. 

25. Plaintiff later learned that her position was not being eliminated, but that Defendants’ 

changed her position title to “Phlebotomist/Registration Specialist.”

26. When Plaintiff asked Defendants why she was being terminated when her office still 

needed a phlebotomist and why Defendants did not consider her for the 

“Phlebotomist/Registration Specialist” based on her fourteen (14) years of experience in that role 

and fifty-three (53) years of lab work experience, Defendants replied that the position would be 

different from her employment and listed several job duties it claimed her prior role did not 

include. 

27. After Plaintiff’s considerable persistence, Defendants allowed Plaintiff to apply for the 

“Phlebotomist/Registration Specialist” position at the office where she had already worked for 

the last fourteen (14) years. 

28. However, Defendants again failed to provide Plaintiff with reasonable accommodations 

that she requested in order to interview and apply for that position. 

29. Plaintiff requested a face-to-face interview for the position because she could not conduct 

a phone interview without a relay operator’s services. Defendants’ representative stated an initial 

phone interview was mandatory and denied Plaintiff’s request1. 

30. After Plaintiff attempted to comply with Defendants’ demand that the initial interview be 

conducted by phone by using a relay operator, Defendants then stated a number of the interview 

questions would not work with a relay operator’s services. 

 

1 Upon information and belief, despite telling Plaintiff that the initial interview was mandatory, at least one other 

applicant for the position from the same office was granted an in-person initial interview. 

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31. Plaintiff then suggested the interview be conducted by email, but Defendants likewise 

denied that request. Defendants stated her application would be rescinded if Plaintiff could not 

interview by phone. 

32. It was only after Plaintiff’s repeated efforts and numerous requests that Defendants finally 

relented and stated she could travel to Columbus for an in-person interview.

33. However, Defendants then required Plaintiff to simultaneously interview with 

approximately five (5) to six (6) interviewers notwithstanding that Plaintiff must read lips to 

communicate and despite the considerable difficulties Plaintiff experienced reading the lips of 

and responding to this many interviewers. 

34. Defendants ultimately terminated Plaintiff’s employment and/or refused to hire her for the 

“Phlebotomist/Registration Specialist” position at the office where she had worked for the last 

fourteen (14) years. 

35. At all times during her employment, Plaintiff was qualified to perform the essential 

functions of her job and/or the “Phlebotomist/Registration Specialist” position with reasonable 

accommodation(s). Refusing to engage in the interactive process and further regularly refusing

provide reasonable accommodations created a hostile work environment. 

36. Plaintiff subsequently filed a charge of disability discrimination with the Equal 

Employment Opportunity Commission (“EEOC”).

37. On September 6, 2017, the EEOC mailed Plaintiff a Notice of Right to Sue to pursue her 

claims under the ADA against Defendants for disability discrimination. 

IV. CAUSES OF ACTION

FIRST CAUSE OF ACTION

29 U.S.C. § 2615, et seq. - FMLA Interference with Rights and Retaliation

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38. All of the preceding paragraphs are realleged as if fully rewritten herein.

39. At all times relevant, Plaintiff was an “eligible employee” as defined by 29 U.S.C. § 

2611(2).

40. At all times relevant, Defendants were an “employer” as defined by 29 U.S.C. § 

2611(4)(A).

41. Plaintiff’s request for, and use of, FMLA leave beginning in or around June of 2016 

through August of 2016 were for her “serious health condition” as defined by 29 U.S.C. § 

2611(11)(B).

42. On or around September 1, 2016, Plaintiff was cleared by her physician to return to work 

without medical restrictions. Plaintiff returned and performed her responsibilities without 

incident.

43. The same month that she returned from FMLA medical leave, Defendants informed

Plaintiff that her position was purportedly being eliminated. 

44. At that same time, Defendants’ human resources representative stated that she had already 

reviewed all of Defendants’ available job postings and there were no openings for Plaintiff. 

45. Plaintiff later learned that her position was not being eliminated, but that Defendants’ 

changed her position title to “Phlebotomist/Registration Specialist.”

46. Defendants ultimately terminated Plaintiff’s employment and/or refused to hire her for the 

“Phlebotomist/Registration Specialist” position at the office where she had worked for the last 

fourteen (14) years. 

47. Pursuant to 29 U.S.C. § 2615(a)(1), it is unlawful for an employer to interfere with an 

employee’s right to exercise FMLA leave. An employer is also prohibited from discriminating or 

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retaliating against an employee who exercises a right under the FMLA. See 29 U.S.C. § 

2615(a)(2).

48. Defendants have willfully and/or recklessly retaliated against, interfered with, restrained, 

and/or denied Plaintiff’s rights in violation of the FMLA, by taking the following non-exhaustive 

list of actions: treating Plaintiff less favorably than similarly situated employees who did not 

exercise rights under the FMLA, by advising Plaintiff that her position was purportedly being 

eliminated shortly after she returned from FMLA leave, by stating that Defendants had already 

reviewed all available job postings and there were no other openings for Plaintiff, by failing to 

advise Plaintiff that her phlebotomist position was not being eliminated, but that Defendants’ had 

changed her position title to “Phlebotomist/Registration Specialist”, by failing to consider 

Plaintiff for the “Phlebotomist/Registration Specialist” based on her fourteen (14) years of 

experience in that role and fifty-three (53) years of lab work experience, and by ultimately 

terminating Plaintiff’s employment and/or refusing to hire her for the “Phlebotomist/Registration 

Specialist” position at the same office where she worked for the last fourteen (14) years. 

49. Defendants lacked good faith to believe it had not violated the FMLA in their actions. 

50. As a direct and proximate result of Defendants’ actions, Plaintiff has suffered damages, 

including but not limited to lost wages and benefits as well as time and money in endeavoring to 

protect herself from Defendants, including costs and attorneys’ fees in accordance with 29 U.S.C. 

§ 2617(a).

SECOND CAUSE OF ACTION

ADA – Disability Discrimination

51. All of the preceding paragraphs are realleged as if fully rewritten herein.

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52. At all times material herein, Plaintiff was disabled, was regarded as disabled, or had a 

record of being disabled, as defined in 42 U.S.C. § 12112, et seq., of Title I of the Americans with 

Disabilities Act of 1990 (“ADA”), as amended (“ADAAA”), because she suffered from a physical 

impairment that substantially limits her ability to perform several major life activities and/or

impacts major life functions.

53. Defendants knew Plaintiff was disabled, or regarded as disabled, as defined in 42 U.S.C. § 

12102.

54. Defendants treated Plaintiff less favorably than other similarly situated employees without 

disabilities. 

55. Alternatively, Defendants discriminated against Plaintiff because of her disability, record 

of having an impairment, or being regarded as having an impairment as defined in 42 U.S.C. 

§12102(1).

56. Despite her physical impairment(s), Plaintiff was able to perform the essentials functions 

of her job with or without a reasonable accommodation. Accordingly, Plaintiff was an “otherwise 

qualified” individual. 

57. Defendants discriminated against Plaintiff because of her disability, her record of 

disability, or because Defendants regarded Plaintiff as disabled by taking the following nonexhaustive list of actions: failing to engage in the interactive process, failing to accommodate her 

disability, creating a hostile work environment by repeatedly failing to provide reasonable 

accommodations, failing to permit Plaintiff to continue working as a phlebotomist, failing to 

accommodate Plaintiff to interview for the “Phlebotomist/Registration Specialist” position, 

failing to hire Plaintiff for the “Phlebotomist/Registration Specialist”, terminating Plaintiff’s 

employment as a phlebotomist for Defendants due to her disability, and/or by otherwise 

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discriminating against her in the terms, privileges and conditions of employment while other 

similarly-situated employees without disabilities received more favorable treatment.

58. As a direct and proximate result of Defendants’ conduct, Plaintiff has suffered and will 

continue to suffer economic and non-economic damages, including but not limited to emotional 

distress and the loss of compensation, benefits and other terms, privileges and conditions of

employment for which Defendants are liable.

59. Defendants’ conduct was willful, wanton, reckless and/or malicious for which Defendants

are liable for compensatory damages, punitive damages, reasonable attorneys’ fees, costs, and 

other relief available under Ohio Revised Code Chapter 4112.

THIRD CAUSE OF ACTION 

ADA - Failure to Engage in the Interactive Process and Accommodate

60. Plaintiff restates the allegations contained in the preceding paragraphs as if fully rewritten 

herein.

61. Pursuant to 42 U.S.C. § 12112(b)(5)(A), it is unlawful for an employer to not make 

reasonable accommodations to the known physical limitations of an otherwise qualified 

individual with a disability who is an employee.

62. Defendants were aware of Plaintiff's disability.

63. Prior to her termination, Plaintiff requested reasonable accommodations for her disability. 

These reasonable accommodations would not cause any unduly hardship to Defendants.

64. Defendants violated 42 U.S.C. § 12112(b)(5)(A) by failing to accommodate Plaintiff's 

disability, and by failing to engage in a good faith interactive process to determine an objectively 

reasonable accommodation for her disability.

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65. As a direct and proximate result of Defendants’ conduct, Plaintiff has suffered and will 

continue to suffer economic and non-economic damages, including but not limited to serious 

emotional distress and the loss of salary, benefits and other terms, privileges and conditions of 

employment for which Defendants are liable.

66. Defendants’ conduct was willful, wanton, reckless and/or malicious for which Defendants 

are liable for compensatory damages, punitive damages and reasonable attorney’s fees and costs.

FOURTH CAUSE OF ACTION

ADA – Retaliation

67. All of the preceding paragraphs are realleged as if fully rewritten herein.

68. This claim is brought under the ADA, pursuant to 42 U.S.C. § 12203(a), which provides 

that “[n]o person shall discriminate against any individual because such individual has opposed 

any act or practice made unlawful by [the ADA]...” See 42 U.S.C. § 12203(a).

69. Plaintiff engaged in a protected activity by requesting reasonable accommodation for her 

disability – to continue working as a phlebotomist for Defendants and/or to be accommodated to 

interview for the “Phlebotomist/Registration Specialist” and hired for that position. 

70. Defendants knew that Plaintiff engaged in protected activity.

71. Once Plaintiff engaged in the aforementioned protected activity, Defendants purposefully 

retaliated against Plaintiff by taking the following non-exhaustive list of actions: refusing to 

engage in the interactive process, refusing to provide reasonable accommodation, refusing to 

continue employing Plaintiff due to her disability, refusing to consider her for the 

“Phlebotomist/Registration Specialist”, refusing to accommodate Plaintiff to interview for the 

“Phlebotomist/Registration Specialist” due to her disability, refusing to hire Plaintiff for the 

“Phlebotomist/Registration Specialist” position due to her disability, terminating Plaintiff’s 

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employment as a phlebotomist for Defendants due to her disability, and/or by otherwise 

discriminating against her in the terms, privileges and conditions of employment while other 

similarly-situated employees without disabilities received more favorable treatment.

72. As a direct and proximate result of Defendants’ conduct, Plaintiff has suffered and will 

continue to suffer economic and non-economic damages, including but not limited to emotional 

distress and the loss of compensation, benefits and other terms, privileges and conditions of 

employment for which Defendants are liable. 

73. Defendants’ conduct was willful, wanton, reckless and/or malicious for which Defendants

are liable for compensatory damages, punitive damages, reasonable attorneys’ fees, costs, and 

other relief available under the ADA.

FIFTH CAUSE OF ACTION

Ohio Revised Code § 4112.02 – Disability Discrimination 

74. All of the preceding paragraphs are realleged as if fully rewritten herein.

75. At all times relevant herein, Plaintiff was disabled, regarded as disabled, or she had a record 

of a disability, as defined in O.R.C. § 4112.01(A)(13), because she suffered from a physical 

impairment that substantially limits her ability to perform several major life activities and/or 

impacts major life functions.

76. Despite her physical impairment(s), Plaintiff was able to perform the essentials functions 

of her job with or without a reasonable accommodation. Accordingly, Plaintiff was an “otherwise 

qualified” individual. 

77. Defendants knew Plaintiff was disabled, and/or had a record of impairment, and/or

regarded her as disabled.

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78. Defendants discriminated against Plaintiff because of her disability or record of impairment

by taking the following non-exhaustive list of actions: refusing to engage in the interactive 

process, refusing to provide reasonable accommodation, refusing to continue employing Plaintiff 

due to her disability, refusing to consider her for the “Phlebotomist/Registration Specialist”, 

refusing to accommodate Plaintiff to interview for the “Phlebotomist/Registration Specialist” due 

to her disability, refusing to hire Plaintiff for the “Phlebotomist/Registration Specialist” position 

due to her disability, terminating Plaintiff’s employment as a phlebotomist for Defendants due to 

her disability, and/or by otherwise discriminating against her in the terms, privileges and 

conditions of employment while other similarly-situated employees without disabilities received 

more favorable treatment.

79. As a direct and proximate result of Defendants’ conduct, Plaintiff has suffered and will 

continue to suffer economic and non-economic damages, including but not limited to emotional 

distress and the loss of compensation, benefits and other terms, privileges and conditions of 

employment for which Defendants are liable. 

80. Defendants’ conduct was willful, wanton, reckless and/or malicious for which Defendants

are liable for compensatory damages, punitive damages, reasonable attorneys’ fees, costs, and 

other relief available under Ohio Revised Code Chapter 4112.

SIXTH CAUSE OF ACTION

Failure to Engage in the Interactive Process and Accommodate - R.C. § 4112.02

81. Plaintiff restates the allegations contained in the preceding paragraphs as if fully rewritten 

herein.

82. At all times material herein, Plaintiff suffered from a physical impairment within the 

meaning of R.C §4112.01(A)(13) of the Ohio Revised Code.

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83. Defendants were aware of Plaintiff’s disability. 

84. Prior to her termination, Plaintiff requested reasonable accommodations for her disability. 

85. Defendants violated R.C. §4112.02 by failing to accommodate Plaintiff’s disability and by 

failing to engage in a good faith interactive process to determine an objectively reasonable 

accommodation for her disability. 

86. As a direct and proximate result of Defendants’ conduct, Plaintiff has suffered and will 

continue to suffer economic and non-economic damages, including but not limited to serious 

emotional distress and the loss of salary, benefits and other terms, privileges and conditions of 

employment for which Defendants are liable.

87. Defendants’ conduct was willful, wanton, reckless and/or malicious for which Defendants

are liable for compensatory damages, punitive damages and reasonable attorney’s fees and costs.

SEVENTH CAUSE OF ACTION

Ohio Revised Code § 4112.02(I) - Retaliation

88. All of the preceding paragraphs are realleged as if fully rewritten herein.

89. This claim is brought under Ohio law, pursuant to Ohio Revised Code § 4112.02(I), et seq.

90. Plaintiff engaged in a protected activity by requesting reasonable accommodation for her 

disability as described in the preceding paragraphs. 

91. Defendants knew that Plaintiff engaged in a protected activity.

92. Once Plaintiff engaged in the aforementioned protected activity, Defendants purposefully 

retaliated against Plaintiff by taking the following non-exhaustive list of actions: refusing to 

engage in the interactive process, refusing to provide reasonable accommodation, refusing to 

continue employing Plaintiff due to her disability, refusing to consider her for the 

“Phlebotomist/Registration Specialist”, refusing to accommodate Plaintiff to interview for the 

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“Phlebotomist/Registration Specialist” due to her disability, refusing to hire Plaintiff for the 

“Phlebotomist/Registration Specialist” position due to her disability, terminating Plaintiff’s 

employment as a phlebotomist for Defendants due to her disability, and/or by otherwise 

discriminating against her in the terms, privileges and conditions of employment while other 

similarly-situated employees without disabilities received more favorable treatment.

93. As a direct and proximate result of Defendants’ conduct, Plaintiff has suffered and will 

continue to suffer economic and non-economic damages, including but not limited to emotional 

distress and the loss of compensation, benefits and other terms, privileges and conditions of 

employment for which Defendants are liable. 

94. Defendants’ conduct was willful, wanton, reckless and/or malicious for which Defendants 

are liable for compensatory damages, punitive damages, reasonable attorneys’ fees, costs, and 

other relief available under Ohio Revised Code Chapter 4112.

V. PRAYER FOR RELIEF

WHEREFORE, Plaintiff demands lost wages and benefits, front pay and benefits, and 

additional damages to be determined at trial, including but not limited to statutory damages, 

compensatory damages, liquidated damages, punitive damages, pre-judgment interest, postjudgment interest, costs, attorneys’ fees, and all other relief the Court deems just and appropriate. 

Respectfully submitted,

/s/ Matthew J.P. Coffman ____

Matthew J.P. Coffman (0085586)

Coffman Legal, LLC

1457 S. High St. 

Columbus, Ohio 43207

Phone: 614-949-1181

Fax: 614-386-9964

Email: mcoffman@mcoffmanlegal.com

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/s/ Peter A. Contreras 

Peter Contreras (0087530)

CONTRERAS LAW, LLC

PO Box 215

Amlin, Ohio 43002

Phone: 614-787-4878

Fax: 614-923-7369

Email: peter.contreras@contrerasfirm.com

Attorneys for Plaintiff

JURY DEMAND

Plaintiff requests a trial by a jury of eight (8) persons.

/s/ Matthew J.P. Coffman

Matthew J.P. Coffman 

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