Hartigan v. Hall-Dale Manor

CourtSuperior Court of Maine
DecidedFebruary 1, 2005
DocketKENcv-03-202
StatusUnpublished

This text of Hartigan v. Hall-Dale Manor (Hartigan v. Hall-Dale Manor) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hartigan v. Hall-Dale Manor, (Me. Super. Ct. 2005).

Opinion

STATE OF MAINE SUPERIOR COURT

CIVIL ACTION KENNEBEC ss. DOCKET NO. CV-03-202 WO NAA “ kK i ; } cud : oe

DANIELLE HARTIGAN,

Plaintiff

Vv. DECISION AND ORDER

HALL-DALE MAN: OR,

Defendant

FRO 23 005

This matter is before the court on Defendant’s motion for summary judgment pursuant to MLR. Civ. P. 56.

The present complaint involves claims of retaliation in violation of the Maine Whistleblower Protection Act (hereinafter “the WPA” or “the Act’), 26 M.R.S.A. § 831 et seq., (count I) as well as common law defamation (count II). Plaintiff Danielle Hartigan (hereinafter “Plaintiff” or “Hartigan”) was employed by Defendant Hall-Dale Manor d/b/a North Country Residential Care Associates (NCRCA) and North Country Residential Care, Inc. (hereinafter “Defendant” or “Hall-Dale Manor”) between March and August of 2001. Hall-Dale Manor is a residential care facility for disabled adults located in Farmingdale, Maine. Hartigan was hired to work at Hall-Dale Manor as the activities director. In this capacity, Hartigan was responsible for arranging activities for residents both on and off-site. Additionally, the Plaintiff was responsible for overseeing the safety of residents while engaged in these activities.

On or about July 29, 2001, Hartigan attended a resident counsel meeting. As the activities director, the Plaintiff was the only staff member permitted to attend these meetings. During the July 29% meeting, the Plaintiff heard the residents in attendance

discuss various concerns relative to living conditions at Hall-Dale Manor. A day or so 2

after the meeting, Hartigan provided a summary of these concerns to her supervisor. The Plaintiff claims that she informed her supervisor, as well as the head administrator, that she could “go to the state” with these issues if they were not properly addressed.

Chad Cloutier (hereinafter “Cloutier”) was hired by NCRCA to serve as a part- time consultant beginning on August 6, 2001. Cloutier is the stepson of Bernard Davis (hereinafter “Davis’), the general partner of N CRCA. Prior to August 6, 2001, Cloutier had no interest, involvement, or responsibility in the operation of Hall-Dale Manor. On or about August 5, 2001, Davis told Cloutier that he had received a report that there had been breaches of confidentiality with respect to residents of Hall-Dale Manor by Hall- Dale Manor employees. In addition, Davis told Cloutier that he had also received information that a resident of Hall-Dale Manor had fallen and hit her head on a post while on an outing. An internal investigation ensued, resulting in the termination of Hartigan, as well as several other Hall-Dale Manor employees. Cloutier concluded from his investigation that Hartigan had failed to supervise residents and had also violated company policy by discussing confidential information about Hall-Dale Manor residents with employees of Walter’s Boarding Home, where she also worked part- time. Contrarily, Hartigan claims that Davis directed Cloutier to fire her and that his investigation was essentially a sham. The Plaintiff contends that she was really fired because she had threatened to address concerns regarding residents’ rights with the State. Also, she claims that Davis was fearful of having the facility shut down because it Was operating under a conditional license.

Following her termination, the Plaintiff filed a complaint with the Maine Human Rights Commission. The Commission’s investigator determined that there were no

reasonable grounds to conclude that Hall-Dale Manor had violated the WPA when it

fired Hartigan. The Law Court has explained that:

Summary judgment is no longer an extreme remedy. It is simply a

procedural device for obtaining judicial resolution of those matters that

may be decided without fact-finding. Summary judgment is properly

granted if the facts are not in dispute or, if the defendant has moved for

summary judgment, the evidence favoring the plaintiff is insufficient to

support a verdict for the plaintiff as a matter of law. Curtis v. Porter, 2001 ME 158, J 7, 784 A.2d 18, 21-22. Summary judgment is proper if the citations to the record found in the parties’ Rule 56(h) statements demonstrate that there is no genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law. See Dickinson v. Clark, 2001 ME 49, 7 4, 767 A.2d 303, 305. “A fact is material if it has the potential to affect the outcome of the case under governing law.” Levine v. R.B.K. Caly Corp., 2001 ME 77, ¥ 4, n.3, 770 A.2d 653, 655, n.3 (citing Burdzel v. Sobus, 2000 ME 84, { 6, 750 A.2d 573, 575). “The invocation of the summary judgment procedure does not permit the court to decide an issue of fact, but only to determine whether a genuine issue of fact exists. The Court cannot decide an issue of fact no matter how improbable seem the opposing party’s chances of prevailing at trial.” Searles v. Trustees of St. Joseph’s College, 1997 ME 128, 6, 695 A.2d 1206, 1209 (quoting Tallwood Land & Dev. Co. v. Botka, 352 A.2d 753, 755 (Me. 1976)).-To avoid a judgment as a matter of law for a defendant, a plaintiff must establish a prima facie case for each element of her cause of action. See Fleming v. Gardner, 658 A.2d 1074, 1076 (Me. 1995).

The Defendant argues that it is entitled to summary judgment on count I of the complaint because Hartigan cannot show any causal connection between her termination and what she claims was protected activity. Hall-Dale Manor first notes

that the WPA prohibits employers from firing an employee who, in good faith, reports

to their employer or a public body what the employee reasonably believes is a violation 4

of the law. See 26 M.RS.A. § 833(1)(A) (2003). Further, the Defendant notes that to establish a prima facie case of retaliation, Hartigan must show (1) that she engaged in activity protected by the WPA, (2) that she was the subject of adverse employment action, and (3) that there was a causal link between the protected activity and the adverse employment action. See Bishop v. Bell Atlantic Corp., 299 F.3d 53, 58 (1% Cir. 2002); DiCentes v. Michaud, 1998 ME 227, { 14, 719 A.2d 509, 514. In analyzing claims under the WPA, Maine courts have adopted the three-part burden-shifting analysis enunciated in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973). See DiCentes, 1998 ME 227, 7 14, 719 A.2d at 514. Hence, in this case, Hartigan must first meet the minimal burden of establishing a prima facie case. Id. Thereafter, the evidentiary burden shifts to Hall-Dale Manor to set forth a legitimate, non-retaliatory motive for firing her. Id. Finally, the burden shifts back to the Plaintiff, who must establish that the Defendant's stated reasons for the termination are pretextual, and that the real motive was in fact retaliatory. Id.

For the purposes of this motion, the Defendant concedes that Hartigan satisfies the low initial burden of production for establishing a prima facie case of retaliation. Further, Hall-Dale Manor asserts, and Hartigan agrees, that it has met its burden to articulate legitimate, non-discriminatory reasons for her termination. However, the Defendant contends that Hartigan cannot meet her ultimate burden of proof on the issues of pretext and retaliatory motive.

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Related

McDonnell Douglas Corp. v. Green
411 U.S. 792 (Supreme Court, 1973)
Bishop v. Bell Atlantic Corp.
299 F.3d 53 (First Circuit, 2002)
Reeves v. Sanderson Plumbing Products, Inc.
530 U.S. 133 (Supreme Court, 2000)
LaPlante v. United Parcel Service, Inc.
810 F. Supp. 19 (D. Maine, 1993)
DiCentes v. Michaud
1998 ME 227 (Supreme Judicial Court of Maine, 1998)
Burdzel v. Sobus
2000 ME 84 (Supreme Judicial Court of Maine, 2000)
Carey v. Mt. Desert Island Hospital
910 F. Supp. 7 (D. Maine, 1995)
Searles v. Trustees of St. Joseph's College
695 A.2d 1206 (Supreme Judicial Court of Maine, 1997)
Fleming v. Gardner
658 A.2d 1074 (Supreme Judicial Court of Maine, 1995)
Dickinson v. Clark
2001 ME 49 (Supreme Judicial Court of Maine, 2001)
Staples v. Bangor Hydro-Electric Co.
629 A.2d 601 (Supreme Judicial Court of Maine, 1993)
Cole v. Chandler
2000 ME 104 (Supreme Judicial Court of Maine, 2000)
Hill v. Town of Lubec
609 A.2d 699 (Supreme Judicial Court of Maine, 1992)
Curtis v. Porter
2001 ME 158 (Supreme Judicial Court of Maine, 2001)
Tallwood Land & Development Co. v. Botka
352 A.2d 753 (Supreme Judicial Court of Maine, 1976)
Levine v. R.B.K. Caly Corp.
2001 ME 77 (Supreme Judicial Court of Maine, 2001)

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Hartigan v. Hall-Dale Manor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hartigan-v-hall-dale-manor-mesuperct-2005.