On September 10, 2018, Chief U.S. District Judge S. Maurice Hicks, Jr. of the U.S. District Court for the Western District of Louisiana dismissed a lawsuit alleging a Louisiana hospital violated Title VII of the Civil Rights Act by racially discriminating against a former employee. The case was Lawson v. PHC Minden, L.P.
The plaintiff in the case is Theresa Lawson, an African-American registered nurse who started working as a full-time nurse at Minden Medical Center (“MMC”) in July of 2003. Starting in July of 2014, Ms. Lawson became a part-time nurse working night shifts on a PRN basis at MMC. In June 2013, MMC offered Ms. Lawson a full-time nursing position with a daytime schedule, which she accepted. However, after working in the full-time position for only two months, Ms. Lawson decided to go back to working on a PRN basis because the full-time position increased her stress and she could take better care of her mother if she worked nights.
Soon after resigning the full-time day position, Ms. Lawson learned of an opening for a full-time night case manager position at MMC. Ms. Lawson applied for the job, but MMC ultimately promoted Jamie Malone to the position. Ms. Malone, a Caucasian registered nurse, had worked full-time in the ICU at MMC since 2008, and she also had prior supervisory nursing experience at two other hospitals. After the decision was made, one of the supervisors who interviewed Ms. Lawson told her that while all the interviewers agreed Ms. Lawson was qualified for the role, they did not perceive her as enthusiastic or genuinely interested in the role. On March 28, 2016, after first filing charges of discrimination with both the Louisiana Commission on Human Relations and the Equal Employment Opportunity Commission, Ms. Lawson filed suit against MMC alleging that it racially discriminated against her by promoting Ms. Malone to the full-time night case manager position instead of her.
MMC recently filed a motion for summary judgment arguing for the court to dismiss the case because the hospital claimed the promotion decision was made based on legitimate, nondiscriminatory reasons. In response, Ms. Lawson argued that the decision was racially motivated in violation of Title VII because she was clearly more qualified than Ms. Malone and because no other African-Americans were employed by MMC as full-time case managers. The court agreed with MMC and granted summary judgment. The court rejected the argument that Ms. Lawson was clearly more qualified because both nurses were at least minimally qualified for the position and the “record does not present a situation where Lawson’s qualifications ‘leap from the record and cry out to all who would listen that [she] was vastly-or even clearly-more qualified for the subject job.’” The court also found that Ms. Lawson failed to present any evidence establishing a link between the lack of other African-American case mangers at MMC and MMC’s decision to promote Ms. Malone instead of Ms. Lawson. Without such evidence, the court held that Ms. Lawson’s allegations amounted to mere speculations that could not support any inference that MMC’s actions were racially motivated.
The attorneys at Chilivis Grubman represent clients of all types and sizes – particularly in the healthcare industry – in connection with employment-related matters, including those brought under Title VII and similar employment discrimination and retaliation matters. For any questions, or if we can be of any assistance with such a matter, please contact us at (404) 262-6505 or sgrubman@cglawfirm.com.