In Loyd v. Saint Joseph Mercy Oakland, et al., the Sixth Circuit recently upheld a Michigan district court's decision to dismiss a 52-year-old African-American female security guard's age, race and sex discrimination claims arising from her discharge following an incident with a combative psychiatric patient at the hospital where she worked.
Anita Loyd had worked as a security guard at Saint Joseph Mercy Oakland/Trinity Health Hospital for 25 years prior to her termination. During that time, she had several disciplinary problems. After Loyd’s most recent disciplinary infraction, which is detailed below, the hospital placed her on final written-warning status.
The parties did not agree on the details of the incident that led to Loyd's termination.
- The hospital contended that Loyd was dispatched to help the medical staff restrain a combative female psychiatric patient.
- While in the room, Loyd did not help restrain the patient, and instead began questioning why the patient was in the hospital. She then told the patient that she could leave the hospital if she had been admitted for a drug-related or alcohol-related reason as opposed to a psychiatric reason.
According to the hospital, Loyd's actions exacerbated the patient's condition. Fortunately, two other security guards eventually succeeded in restraining the patient. Loyd conceded that the incident occurred, but denied that she failed to help restrain the patient and that the patient became more combative because of her actions.
The hospital began an internal investigation following the incident, which included obtaining statements from witnesses.
After reviewing the results, Loyd's supervisors decided to terminate her employment; they concluded that she had acted outside the scope of her duties and advised a patient incorrectly about the patient’s ability to leave the premises, which resulted in an exacerbation of the patient's condition. Since her conduct constituted a major infraction of the hospital's disciplinary policy and she was already on final written warning, the infraction resulted in immediate discharge. The hospital then hired a 39-year-old African-American woman to fill Loyd's position.
Suit Filed in Federal District Court
After receiving a right-to-sue letter from the EEOC, Loyd filed suit against the hospital and five hospital employees in federal district court. The hospital filed a motion for summary judgment on all of Loyd's claims, which the district court granted and entered judgment in favor of the hospital.
The court held that Loyd could not establish a prima facie case of age, race or sex discrimination because she could not demonstrate that she was qualified for the security guard position, since she had not performed her job at a level to meet the hospital's legitimate expectations. The district court further held that Loyd could not show that the hospital's proffered reason for firing her was pretextual and intended to disguise unlawful discrimination. The court also dismissed Loyd's common law claims of intentional interference with a contractual relationship and intentional infliction of emotional distress as preempted by the Labor Management Relations Act.
U.S. Court of Appeals for the Sixth Circuit Opinion
On appeal, the Sixth Circuit found that the district court did not err in granting the hospital's motion for summary judgment on the race, sex and age discrimination claims, but it did not adopt the same reasoning as the district court. While the district court held that the plaintiff had failed to establish that she was qualified for the position, the Sixth Circuit found that since Loyd had been replaced by another African-American female, she could not establish that she was replaced by someone outside of the protected class, regardless of whether she was qualified for the position.
With respect to the age discrimination claim, the circuit court actually concluded that the district court had erred in ruling that she had not established that she was qualified for the position. The circuit court believed that the fact that she had worked as a security guard at the hospital for 25 years was compelling evidence that she met the hospital's objective minimum qualifications for the job.
The district court's error had stemmed from the court’s conflation of the qualification prong with the hospital’s nondiscriminatory reason for terminating Loyd’s employment. The district court had improperly focused on the hospital’s proffered reason for terminating Loyd rather than on Loyd’s objective qualifications for the security guard position in evaluating her prima facie case.
Having found that Loyd was qualified for the position and therefore had satisfied the requirements of making out a prima facie case, the circuit court then looked to whether the hospital had satisfied its burden of offering a legitimate nondiscriminatory justification.
- The court held that the hospital took witness statements, made a reasonable assessment of the available evidence and terminated Loyd for committing a major infraction while on final written warning status.
- Loyd had not demonstrated that the proffered nondiscriminatory reason was pretextual, so the court ruled that her age discrimination claim must fail.
- The court further upheld the district court's granting of summary judgment with regard to the common law claims of intentional interference with a contractual relationship and intentional infliction of emotional distress.
What Does This Means for Employers?
Employers should take note of the importance of documenting disciplinary infractions and conducting a thorough investigation into a workplace incident, as demonstrated with this case.
While the courts disagreed as to the reasoning why the plaintiff’s claims failed, both found that the employer offered a legitimate nondiscriminatory justification for its actions based on its internal investigation.