Jackson v. VHS Detroit Receiving Hospital, Inc., 814 F.3d 769 (2016)

In Jackson v. VHS Detroit Receiving Hospital, Inc., the United States Court of Appeals for the Sixth Circuit held that a female mental health technician presented sufficient evidence to establish a prima facie case of sex discrimination under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq. The plaintiff, employed at the Mental Health Crisis Center of Detroit Receiving Hospital, was terminated shortly after she assisted a nurse in discharging a patient who should not have been released. Despite consistently positive performance evaluations, she was fired within days of the incident. The plaintiff alleged that her termination constituted sex discrimination because two male employees committed nearly identical errors of comparable seriousness but were not terminated. The district court granted summary judgment for the hospital, finding no evidence of discriminatory treatment. The Sixth Circuit reversed, holding that the plaintiff established a prima facie case under the McDonnell Douglas burden-shifting framework by showing that similarly situated male employees were treated more favorably. The Court emphasized that the comparators engaged in nearly identical conduct (both errors in patient discharge procedures), but were not disciplined to the same degree. The Court concluded that the evidence created a genuine issue of material fact regarding whether the employer’s stated reason for termination was pretextual. The case was remanded for trial to determine whether the hospital’s decision was motivated by sex discrimination. On remand, the United States District Court for the Eastern District of Michigan again entered judgment in favor of the defendant. See: Jackson v. VHS Detroit Receiving Hosp., Inc., No. 2:14-cv-11600 (E.D. Mich. Sept. 12, 2017). The district court found that the plaintiff failed to prove by a preponderance of the evidence that sex was a motivating factor in the termination and concluded that the hospital’s decision was based on legitimate, nondiscriminatory reasons.

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  • 2016

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Jurisdiction