Glascock v. Linn County Emergency Medicine, PC

855 F. Supp. 2d 866, 2012 WL 45419, 2012 U.S. Dist. LEXIS 2627
CourtDistrict Court, N.D. Iowa
DecidedJanuary 9, 2012
DocketNo. C10-66 EJM
StatusPublished

This text of 855 F. Supp. 2d 866 (Glascock v. Linn County Emergency Medicine, PC) is published on Counsel Stack Legal Research, covering District Court, N.D. Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Glascock v. Linn County Emergency Medicine, PC, 855 F. Supp. 2d 866, 2012 WL 45419, 2012 U.S. Dist. LEXIS 2627 (N.D. Iowa 2012).

Opinion

ORDER

EDWARD J. McMANUS, District Judge.

This matter is before the court on defendant’s resisted Motion for Summary Judgment, filed July 15, 2011. Briefing concluded on August 22, 2011. Granted.

[868]*868Plaintiff Glascock initially brought this action seeking damages and equitable relief against defendant Linn County Emergency Medicine (LCEM) in the Iowa District Court for Linn County on March 31, 2010, in the following counts: Count 1— Pregnancy Discrimination in violation of IC § 216; Count 2 — Pregnancy Discrimination in violation of 42 U.S.C. § 2000e et seq.; Count 3 — Sex Discrimination in violation of IC § 216; Count 4 — Sex Discrimination in violation of 42 U.S.C. § 2000e et seq.; Count 5 — Discrimination Based on National Origin in violation of IC § 216; and Count 6 — Discrimination Based on National Origin in violation of 42 U.S.C. § 2000e et seq.

Defendant removed the matter to this court on April 28, 2010, pursuant to 28 U.S.C. §§ 1441 and 1446. The court has jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1367.

LCEM, an Iowa professional corporation, has an agreement with nonparty Mercy Medical Center (Mercy) in Cedar Rapids, Iowa, to provide physicians to patients at Mercy’s Emergency Department. Plaintiff, a physician, alleges that on August 15, 2007, she was employed by LCEM to treat patients at Mercy’s Emergency Department, and was to be offered an ownership position in LCEM following one year of satisfactory performance of professional service, if approved by a majority of LCEM’s owners. Plaintiff was not offered an ownership position at the end of the first year, but was offered a six month extension of the probationary period. Plaintiff alleges that on January 27, 2009, she was advised her employment would be terminated within ninety days. She alleges that during her employment with LCEM, she was the subject of sex discrimination, pregnancy discrimination, and discrimination based upon national origin, and seeks relief as set forth in Counts 1-6 of her Petition.

Defendant seeks summary judgment, asserting that neither Title VII of the Civil Rights Act of 1964 (Title VII), 42 U.S.C. § 2000e et seq., nor the Iowa Civil Rights Act (ICRA), IC § 216, provide protections to independent contractors. Defendant asserts that it is a corporation consisting of physician shareholders providing medical services as independent contractors, that plaintiff was an independent contractor rather than an employee of LCEM, and therefore her claims are not cognizable under Title VII or the ICRA. Additionally, defendant asserts that Title VII and the ICRA require entities to have a minimum number of employees as a condition of applicability of the Acts, and that LCEM does not have the requisite number of employees to be subject to either Act. Finally, defendant asserts that plaintiff cannot make out discrimination claims as set forth in her Petition. Accordingly, defendant asserts it is entitled to summary judgment.

Fed.R.Civ.P. 56(c) provides that summary judgment shall be entered if the “pleadings, depositions, answers to interrogatories, and admissions on file together with the affidavits, if any, show that there is not a genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law.” In deciding whether to grant a motion for summary judgment, the district court must view the evidence in favor of the party opposing the motion and give him the benefit of all reasonable inferences. Kegel v. Runnels, 793 F.2d 924, 926 (8th Cir.1986). However, parties opposing a summary judgment motion may not rest merely upon the allegations in their pleadings. Buford v. Tremayne, 747 F.2d 445, 447 (8th Cir. 1984). The opposing parties must resist the motion by setting forth specific facts showing that there is a genuine issue of material fact for trial. Id., (citing Fed. [869]*869R.Civ.P. 56(e) and Burst v. Adolph Coors Co., 650 F.2d 980, 932 (8th Cir. 1981)).

Green v. St. Louis Housing Authority, 911 F.2d 65, 68 (8th Cir.1990).

Neither the provisions of Title VII, nor the ICRA, apply to independent contractors. Schwieger v. Farm Bureau Ins. Co. of Nebraska, 207 F.3d 480, 483 (8th Cir.2000) (Title VII); Wortham v. American Family Insurance Group, 385 F.3d 1139, 1141 (8th Cir.2004) (Title VII and ICRA). Whether a person is an employee or an independent contractor is a function of the totality of the employment relationship, applying principles of agency law. Nationwide Mutual Ins. Co. v. Darden, 503 U.S. 318, 323-24, 112 S.Ct. 1344, 117 L.Ed.2d 581 (1992); Wojewski v. Rapid City Regional Hospital, Inc., 450 F.3d 338, 342-43 (8th Cir.2006). “A primary consideration is the hiring party’s right to control the manner and means by which a task is accomplished.” Schwieger, supra, 207 F.3d at 484 (citations omitted). The Darden Court identified twelve other factors to be considered:

Among the other factors relevant to this inquiry are the skill required; the source of the instrumentalities and tools; the location of the work; the duration of the relationship between the parties; whether the hiring party has the right to assign additional projects to the hired party; the extent of the hired party’s discretion over when and how long to work; the method of payment; the hired party’s role in hiring and paying assistants; whether the work is part of the regular business of the hiring party; whether the hiring party is in business; the provision of employee benefits; and the tax treatment of the hired party.

Darden, 503 U.S. at 323-324, 112 S.Ct. 1344 (citation omitted).

Beginning with the matter of control over the manner and means by which the task is accomplished, LCEM tracked and counseled plaintiffs work as to productivity and patient complaints, and provided periodic evaluation, including identification of a number of areas requiring improvement before plaintiff could be offered partnership.

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855 F. Supp. 2d 866, 2012 WL 45419, 2012 U.S. Dist. LEXIS 2627, Counsel Stack Legal Research, https://law.counselstack.com/opinion/glascock-v-linn-county-emergency-medicine-pc-iand-2012.