Secretly Depositing Money Into Inmate’s Account Costs Corrections Officer His Job

Joseph Greenawalt was employed at the Clarion County, Pennsylvania jail as a corrections officer. At the time of his termination, Greenawalt was 58 years old.

Inmate Kelly Zacharias and Greenawalt met when Zacharias was incarcerated at the Clarion County jail. In December 2007, Zacharias began to tell Greenawalt about her lack of money. Greenawalt then began giving her approximately $20.00 per week. Greenawalt mailed the money to Zacharias under an alias to hide his identity. At times while discharging his duties at the jail, Greenawalt would be responsible for recording the receipt of money and would log the money he sent to Zacharias under his alias. Greenawalt knew that all inmate mail would be checked for contraband, and that a log was kept of all monies received by inmates, which included the sender’s name.

When the warden learned from other corrections officers that Greenawalt may have been giving money to Zacharias, an investigation was started. Eventually, the County concluded that approximately $600.00 to $700.00 had been deposited into Zacharias’ prison account by a “JC White,” an alias for Greenawalt. When Greenawalt was fired, he sued the County, claiming that he was the victim of age and gender discrimination.

The linchpin in Greenawalt’s argument was that the County had treated similarly-situated employees more leniently, leading to an inference that its decision to discharge him was motivated by discrimination. A federal trial court saw it differently.

As the Court found, “Greenawalt has not shown that he was treated differently than similarly-situated corrections officers. None of the examples Greenawalt cites include behavior similar to what he admittedly did, covertly deposited money into a current inmate’s account. We have carefully reviewed each of Greenawalt’s asserted comparators and have found that all of Greenawalt’s examples deal with corrections officers who developed social relationships with inmates after the inmates left Clarion County jail.

“Greenawalt attempts to draw a closer comparison between himself and correctional officer Ms. Mangiantini because Mr. Fink complained that she was behaving inappropriately with inmates, was warned for being too friendly with inmates, and was put under investigation by Warden Hornberger. Warden Hornberger’s investigation did not reveal any evidence that Ms. Mangiantini had entered into a relationship with a current inmate. Thus, Greenawalt has not shown that he and Ms. Mangiantini engaged in the same conduct without such differentiating or mitigating circumstances that would distinguish their conduct or their employer’s treatment of them for it.

“Ms. Mangiantini did not covertly deposit money into a current inmate’s account at the Clarion County jail. Ms. Mangiantini’s violation of the policy involved her developing a romantic relationship and eventually marrying an inmate after he was released. The circumstances surrounding Ms. Mangiantini’s and Greenawalt’s violation of the policy are distinguishable such that it was reasonable for Clarion County to treat their offenses differently.”

Greenawalt v. Clarion County, Slip Copy, 2011 WL 1585306 (W.D. Pa. 2011).

This article appears in the June 2011 Issue