Emeritus Corporation v. Lillian Blanco

CourtCourt of Appeals of Texas
DecidedJuly 6, 2011
Docket08-09-00007-CV
StatusPublished

This text of Emeritus Corporation v. Lillian Blanco (Emeritus Corporation v. Lillian Blanco) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Emeritus Corporation v. Lillian Blanco, (Tex. Ct. App. 2011).

Opinion

COURT OF APPEALS

EIGHTH DISTRICT OF TEXAS

EL PASO, TEXAS



EMERITUS CORPORATION,


                                    Appellant,


v.


LILLIAN BLANCO,


                                    Appellee.

§



No. 08-09-00007-CV


Appeal from

 County Court at Law No. 5


of El Paso County, Texas


(TC # 2007-2865)

O P I N I O N


            We decide today that an employee may pursue a private cause of action for retaliatory discharge against an assisted living facility. Emeritus Corporation appeals from a judgment in excess of $134,000 plus post-judgment interest in favor of former employee, Lillian Blanco. For the reasons that follow, we affirm.

FACTUAL SUMMARY

            Emeritus Corporation owns and operates over four hundred assisted living facilities throughout the United States, including four properties in El Paso. Lillian Blanco began working for Emeritus in July 2006, at the company’s El Paso facility known as The Palisades. In September, she was promoted to Interim Executive Director and transferred to the company’s Cambria facility. Cambria is composed of two separate units. Residents in the assisted living unit had very few restrictions on movement within and outside the facility. The Special Care or Memory Alzheimer’s Unit is monitored and secured for patient safety. The residents in the Special Care Unit required significantly more medical attention and daily care than the assisted living unit residents. Up to eighty residents lived at the Cambria facility.

            At the time Blanco arrived at the facility, Cambria had been under continual review by the Texas Department of Aging and Disability Services for several months. In September, the Department notified Emeritus of its intention to deny the application for renewal of Cambria’s operating license due to the number of regulatory violations. The recorded violations included documentation and reporting errors, issues with medication, and problems between patients in the Alzheimer’s Unit. During Blanco’s initial three months at Cambria, Emeritus sent medical and administrative support staff to assist with the implementation of the Plan of Correction developed by Blanco and the company’s Director of Clinical Services, Patsy Grider.

            Cambria’s licensing problems continued through the months of September and October. On November 9, 2006, Emeritus received notice from the Department indicating that it still intended to deny renewal despite additional documentation and evidence regarding operations. Emeritus subsequently was granted an informal reconsideration of the application. Once again, the Department refused to alter its decision. Finally, on November 22, 2006, Department inspectors conducted a follow-up on-site review and noted that the facility had achieved substantial compliance. Emeritus received official notice of the Department’s decision to grant Cambria’s renewal application on January 19, 2007.

            Following the November inspection and determination that Cambria was in substantial compliance with state regulations, Emeritus began withdrawing resources which had been available to Blanco during Cambria’s licensing difficulties. On November 30, 2006, Blanco received an e-mail from Deborah Montgomery, Regional Director of Quality Services assigned to the El Paso facilities, indicating that Cambria was over-budget and instructing Blanco to reduce staff hours by thirty hours per day. Staff reduction was primarily to be implemented by reducing the hours worked by the facility’s registered nurses, certified nursing assistants, and medical technicians. According to Blanco, the reduction meant that Cambria did not have an adequate number of staff members at the facility at a given time to provide for the needs of the residents in both units. Staff worked in three shifts: 7 a.m. to 3 p.m., 3 p.m. to 11 p.m., and 11 p.m. to 7 a.m. After the schedule reduction, Cambria’s 11 p.m. to 7 a.m. shift, the night shift, was reduced to two staff members. One staff member was dedicated to each unit during a shift. In addition to patient care, the night staffers had additional duties including vacuuming, preparing the dining room for breakfast, and patient laundry in the assisted living unit, while the Special Care Unit staffers also changed linens as needed and bathed residents according to a facility schedule. The medical technician, who was responsible for dispersing medication, did not work the night shift. When a patient needed medication or medical attention during the night shift, Blanco was forced to call an off-duty medical technician or have the patient transported to the emergency room. When the night shift staff complained about being overloaded during their shifts, Blanco voiced concerns to other Emeritus administrators. She was told that the facility had to stay within the allotted budget. To compensate, employees were asked to extend their shifts by starting early or staying late to create a shift overlap.

            Blanco also had problems maintaining Cambria’s nursing staff. The staff nurse at the time Blanco arrived at the facility asked to have her duties cut to those of a medical technician because of the amount of work required. The next nurse to come on staff resigned after approximately two months. In December, Emeritus assigned another nurse but after several patient mix-ups and her inability to keep patient records current, she also left the facility. The next nurse resigned due to work overload. When Blanco found yet another replacement, Emeritus immediately transferred the new-hire to another El Paso facility. According to Blanco, Emeritus moved employees through Cambria on a regular basis. Employees would work at the facility for short periods of time, and then be transferred to one of the company’s other facilities, sometimes leaving Cambria without a nurse on staff.

            During one of the periods when the facility was without a staff nurse, Blanco was called to an Alzheimer patient’s room in the Special Care Unit, where the patient was lying in bed with a “mass” protruding from her body. Blanco called a nurse from another Emeritus facility who checked the patient and told Blanco that the mass was a prolapsed uterus. The patient suffered from multiple issues while waiting for surgery. Without a nurse at the facility, Blanco personally assumed the coordination of the woman’s medical care. When Blanco’s reported this and other incidents to company administrators, Emeritus did not provide additional support. In January 2007, in the midst of the facilities staffing problems, Emeritus formally reprimanded Blanco, claiming that Cambria had fallen behind on billing. Blanco attributed this reprimand and subsequent negative feedback to ongoing disputes with her supervisors over staff and hours.

            Blanco became ill in early March. She suffered sleep disruptions and migraine headaches. Her doctor diagnosed her with shingles, and ordered her off work from March 8 to March 13. She faxed her doctor’s explanation to her supervisor immediately. After three fax attempts, which her supervisor denied receiving, a friend hand delivered the note.

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Emeritus Corporation v. Lillian Blanco, Counsel Stack Legal Research, https://law.counselstack.com/opinion/emeritus-corporation-v-lillian-blanco-texapp-2011.