The Third Circuit Court of Appeals reversed a district court's dismissal of an employment discrimination case, ruling that Pennsylvania's fair hiring laws protect job applicants even when they voluntarily disclose their criminal history rather than having it discovered through background checks.

In *Rodney Phath v. Central Transport LLC*, decided Jan. 28, 2026, a three-judge panel unanimously held that Pennsylvania law limiting employers' use of applicants' criminal histories applies regardless of how the employer learns about past convictions. The decision allows Phath's lawsuit against the trucking company to proceed.

Phath applied for a truck driving position with Central Transport LLC, presenting strong qualifications including a commercial driver's license, relevant experience, and federal clearance to access secure ports. During the hiring process, when the company indicated it would conduct a criminal background check, Phath voluntarily disclosed a 15-year-old armed robbery conviction for which he had served six years in prison.

Central Transport immediately rejected Phath's application based solely on this disclosure, leading him to file suit under Pennsylvania state law that restricts how employers may use applicants' criminal histories in hiring decisions.

The U.S. District Court for the Eastern District of Pennsylvania initially dismissed the case, reasoning that Pennsylvania's fair hiring statute did not apply because Central Transport learned about the conviction directly from Phath rather than from state agency files or background check reports.

Writing for the Third Circuit panel, Circuit Judge Stephanos Bibas acknowledged the challenges facing job seekers with criminal records, noting that "job hunting is never easy; having a criminal conviction makes it much harder." The court emphasized that Pennsylvania law exists specifically to address these difficulties by limiting when and how employers may use criminal history information.

The appeals court rejected the district court's narrow interpretation of the statute, holding that the law's protections extend to all uses of criminal history information in employment decisions, regardless of the source. "Even though the company learned of the conviction from him, not from a state agency's files, the law still applies," Judge Bibas wrote.

This interpretation aligns with the broader policy goals underlying Pennsylvania's fair hiring legislation, which aims to provide meaningful opportunities for individuals with criminal records to obtain employment and reintegrate into society. The decision prevents employers from circumventing the law's protections simply by asking applicants to self-report criminal history.

The case highlights the complex legal landscape surrounding employment discrimination based on criminal history. While federal law does not explicitly prohibit such discrimination, many states have enacted "ban the box" and similar fair hiring laws that restrict employers' ability to inquire about or consider criminal records, particularly for older or less serious offenses.

Pennsylvania's statute is part of a growing trend of state-level legislation designed to reduce barriers to employment for individuals with criminal records. These laws typically require employers to conduct individualized assessments considering factors such as the nature of the offense, time elapsed since conviction, and relevance to the specific job duties.

The Third Circuit's decision could have broader implications for how courts interpret fair hiring statutes across jurisdictions. By focusing on the law's protective purposes rather than technical distinctions about information sources, the ruling suggests courts should adopt expansive readings of such legislation.

For employers, the decision underscores the importance of understanding and complying with state fair hiring laws, particularly regarding the timing and manner of criminal history inquiries. Companies operating in multiple states must navigate varying requirements about when such inquiries may be made and how criminal history information may be used in hiring decisions.

The case also demonstrates the value of voluntary disclosure by job applicants. While Phath's honesty about his criminal record initially led to his rejection, it ultimately positioned him to challenge the company's hiring practices under state law protections.

Central Transport has not indicated whether it will seek further review of the decision. The case will now return to the district court for further proceedings, where Phath will have the opportunity to prove his claims under Pennsylvania's fair hiring statute.

The Third Circuit panel included Circuit Judges Stephanos Bibas, Anthony Scirica, and Joseph Smith. The case was argued on Oct. 29, 2025, and decided on Jan. 28, 2026. The original district court case was heard by Judge John R. Padova in the Eastern District of Pennsylvania.

This decision adds to a growing body of case law interpreting state fair hiring statutes and could influence how other federal circuits approach similar questions about the scope and application of criminal history employment protections.