Harrigan-Braxton v. Temple University Hospital

CourtDistrict Court, E.D. Pennsylvania
DecidedJuly 25, 2023
Docket2:21-cv-05240
StatusUnknown

This text of Harrigan-Braxton v. Temple University Hospital (Harrigan-Braxton v. Temple University Hospital) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Harrigan-Braxton v. Temple University Hospital, (E.D. Pa. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA JEANETTE HARRIGAN-BRAXTON, et al., : Plaintiffs, : CIVIL ACTION : No. 21-5240 v. : TEMPLE UNIVERSITY HOSPITAL, INC. Defendant. : MEMORANDUM Schiller, J. July 25, 2023 Plaintiffs Jeanette Harrigan-Braxton, Charles Bowen, and Bunny Verette claim their employer Defendant Temple University Hospital (1) did not promote them to either of two management positions because they are African American and over age forty and (2) retaliated against them with written warnings after they went to Human Resources with a discrimination complaint. Temple Hospital moves for summary judgment on all their claims. Plaintiffs did not respond to the motion. The Court grants Temple Hospital’s unopposed Motion because there are no genuine issues of material fact. It has demonstrated it is entitled to judgment as a matter of law. I. BACKGROUND Temple Hospital employs each Plaintiff as a full-time social worker at its Episcopal Campus (“Episcopal Hospital”): Harrigan-Braxton beginning in 2013, Bowen beginning in 2004, and Verette beginning in 2006. (Def.’s Stmt. of Undisputed Facts, ECF 9, 5-7.) Each Plaintiff is African American and over age fifty. Ud. § 9.) Episcopal Hospital “provides inpatient and outpatient behavioral and primary care services, maintains 118 psychiatric beds, 21 medical beds, and” Philadelphia’s “largest mental health crisis response center... .” Ud. § 1.) Plaintiffs’ duties “include interacting with mental health patients, attending team treatment meetings, interacting with insurance companies, overseeing patient housing applications, meeting with patients’ family

members, and performing discharge planning.” (/d. ¥ 8.) Plaintiffs’ claims involve Episcopal Hospital’s decisions not to promote them to either: (1) Director of Utilization Management and Behavioral Health Therapy (“SUMBHT Director”); or (2) Supervisor of Behavioral Health Services. Ud. §§ 2-3.) Instead, another full-time Episcopal social worker, Kelly Kulp—who is Caucasian and was under age 40 at all relevant times—was promoted to UMBHT Director in July 2018. Ud. § 10.) And in October 2018, Victoria Tuman, who is also Caucasian and under 40, was promoted to Supervisor. Ud. J 11.) A. The UMBHT Director Vacancy In March 2018, then-Director of Behavioral Health Doris Quiles announced her retirement. (id. § 13.) L.R. Rasi (Caucasian, over 40), then the UMBHT Director, applied for and received a promotion to her position, becoming Episcopal Hospital’s Director of Behavior Health, who oversaw the UMBHT Director and Supervisor positions. (Id. 4, 13, 15.) Four Episcopal Hospital social workers applied to fill the newly-vacant UMBHT Director position: Plaintiffs Harrigan and Bowen along with Kulp and Madeline Hotz (Caucasian, under 40).! (Id. § 14.) A three-person panel interviewed the UMBHT Director Applicants: Rasi, Sean Miller (Caucasian, under 40, who was a Supervisor at that time), and Yasser Al-Khatib (Middle Eastern, over 40, and, at the time, the Chief Nursing Officer). Ud. { 15.) Rasi and Miller jointly interviewed the four applicants and Al-Khatib interviewed them by himself. Ud. § 16.) The panel members completed Human Resources’ Interview Evaluation Forms for each applicant to score applicants “in an objective standardized way” on “ten different skill sets, as well as on their strengths and weaknesses” and marked whether they would “recommend hiring this candidate.” (/d.) Kulp received 113 points,

l Verette alleges he was not interviewed for the UMBHT Director position although he submitted a timely online application. (ECF 9, § 14 n.2.) However, there is no evidence he successfully completed the online application. (/d.)

Hotz: 100, Harrigan: 90, and Bowen: 86. Ud. § 19.) Rasi also took simultaneous interview notes about each applicant’s responses to questions about “management experience, familiarity with various software programs, experience performing 15 tasks required of the UMBHT Director, ideas for efficiency improvements, and thoughts on leadership.” Ud. § 17.) When the interviews were completed, the panel members met and “were in agreement that Kelly Kulp was by far the best choice.” Ud. § 18.) Each panel member recommended hiring Kulp on their Interview Evaluation Form and none recommended hiring any other applicant. (/d.) “Kulp had experience performing all 15 tasks required of the UHMBH Director while Ms. Harrigan and Mr. Bowen had performed, respectively, just 8 and 11 of those tasks.” Ud. § 20.) As a result, Rasi decided to promote Kulp to the UMBHT Director position, submitted necessary paperwork to HR, and Kulp accepted the position when it was offered to her. (Ud. § 21.) B. The Supervisor Vacancy A Supervisor vacancy opened after Sean Miller announced his plan to leave Episcopal Hospital in September 2018. Ud. ¢ 22.) All Behavioral Health Staff were notified of the opening and eight out of ten Episcopal Hospital social workers applied, including all three plaintiffs (Harrigan-Braxton, Bowen and Verette), along with Hotz, Victoria Tuman (Caucasian, under 40), Yvonne Coffee (African American, over 40), Nancy Tran (Asian American, under 40), and Naja Hall (African American, under 40). Ud. J 22.) Kulp asked the two social workers who had not applied for the opening and all behavioral health therapists to consider volunteering for a panel to interview and select a new Supervisor. (/d. { 23.) Both non-applicant social workers and one behavioral health therapist volunteered to join the interview panel which ultimately included Rasi, Kulp, behavioral health therapist Venus Weaver (African American, over 40), and social workers John Berrios (African American/Latino, under 40) and Lauren Scarpiello (Caucasian, under 40).

Before conducting interviews, the interview panel for the Supervisor opening met to decide what questions to ask the applicants and who should ask the questions, resulting in a set of “Supervisor Screener” documents. (/d. § 24.) Supervisor applicants “were asked unbiased questions” and “objectively scored in ten categories based on their responses... .” Ud. 4 25.) Each panel member noted applicants’ strengths and weaknesses on a form and indicated whether they would recommend them for promotion. (/d.) Rasi took handwritten notes reflecting “each applicant’s responses to questions on the Supervisor Screeners ... .” (id. { 26.) Panelists anonymously submitted completed forms to an administrative assistant along with pre-printed slips of paper identifying their top three candidates by circling applicants’ initials. 7d. § 25-26.) When the interview panel reconvened to discuss applicants, panel members received packets including a spreadsheet tallying applicants’ numerical scores, a chart listing applicants’ strengths and weaknesses, completed Supervisor Screener documents, and a list of how many top-three votes each applicant received. Ud. § 27.) Tuman and Hotz tied for the top objective interview score on the Interview Evaluation Forms, scoring 248 points each. Ud. § 28.) In contrast, the three Plaintiffs received the lowest scores of the eight Supervisor applicants. (/d.) Harrigan received 189 points, a sixth-place score. (/d.) Bowen landed seventh with 179 points. (/d.) Verette received 177 points, the lowest (eighth- place) score. (/d.) Tuman was the only applicant with a Certified Advanced Alcohol and Drug Counsel credential and was the only applicant who had already won Episcopal Hospital’s exceptional employee award. (/d. § 31.) Tuman also was the only applicant who each of the five interview panel members “recommended” for hiring at the bottom of their Interview Evaluation Forms and was the only applicant in each panel member’s identified “top 3.” Ud. § 30.) In contrast,

Verette received five “no” votes on the Evaluation Form’s “recommendation question.” (/d.) Bowen received four “no” votes. (/d.) Harrigan received three.

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Bluebook (online)
Harrigan-Braxton v. Temple University Hospital, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harrigan-braxton-v-temple-university-hospital-paed-2023.