Hawkins v. Center for Spinal Surgery

247 F. Supp. 3d 897, 2017 WL 1131692, 2017 U.S. Dist. LEXIS 44330
CourtDistrict Court, M.D. Tennessee
DecidedMarch 27, 2017
DocketCase No. 3:12-CV-1125
StatusPublished
Cited by1 cases

This text of 247 F. Supp. 3d 897 (Hawkins v. Center for Spinal Surgery) is published on Counsel Stack Legal Research, covering District Court, M.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hawkins v. Center for Spinal Surgery, 247 F. Supp. 3d 897, 2017 WL 1131692, 2017 U.S. Dist. LEXIS 44330 (M.D. Tenn. 2017).

Opinion

[900]*900MEMORANDUM

KEVIN H. SHARP, UNITED STATES DISTRICT JUDGE

Pending before the Court are two of Defendant, The Center for Spinal Surgery’s (“CSS”), motions. First, CSS filed a Renewed Motion for Directed Verdict on Plaintiffs Claim for Retaliation Pursuant to Fed. R. Civ. P. 50(b) or, in the Alternative, Motion for a New Trial Pursuant to Fed. R. Civ. P. 59. (Docket No. 264). Second, CSS filed a Renewed Motion for Judgment as a Matter of Law on Punitive Damages; or, in the Alternative, Motion for a New Trial; or, in the Alternative, Motion for Remittitur. (Docket No. 266). Plaintiff Demica D. Hawkins (“Ms. Hawkins”) filed a Response to each motion. (Docket No. 269). CSS filed Replies. (Docket Nos. 290 & 291). Having reviewed the motions and briefs, the Court will deny both of CSS’s Motions for Judgment as a Matter of Law.1 (Docket Nos. 264 & 266). The Court will recommend a remittitur of $73,225.55, which will reduce the punitive damages award to $219,676.65. The Court will conditionally grant CSS’s Motions for a New Trial. (Docket Nos. 264 & 266).

BACKGROUND

Ms. Hawkins is a black woman who worked as an Accounts Payable Coordinator within CSS’s Business Department. Ms. Hawkins was employed in this role at CSS from February 2009 until March 1, 2013. Throughout her employment, Ms. Hawkins filed two separate EEOC complaints claiming racial discrimination and retaliation by CSS.

Following the EEOC process, Ms. Hawkins filed this suit on October 30, 2012. At the time Ms. Hawkins filed this lawsuit, she was in the third trimester of pregnancy. She accordingly filed for and received FMLA maternity leave from CSS, and Ms. Hawkins began her leave on December 12, 2012, with a presumptive return date of March 1, 2013. On January 28, 2013, Ms. Hawkins received a letter from Kathy Watson, Administrator in Chief of Nursing for CSS, informing Ms. Hawkins that her position was being eliminated. In Ms. Watson’s letter, she stated that the hospital was implementing a new electronic health records system called Cerner; that Ms. Hawkins’ accounts payable function was no longer needed under the new system; that all twelve of the sister hospitals were impacted by the changes; that CSS was transferring its revenue cycle functions to a facility in Texas; and that at least two other positions within CSS’s business office were also being eliminated as part of the transition.

Following her termination, Ms. Hawkins filed an Amended Complaint that included claims for retaliation and discrimination under Title VII, 42 U.S.C. § 2000e et seq.; 42 U.S.C. § 1981; the Tennessee Human Rights Act (“THRA”), Tenn. Code Ann. § 4—21—101(a)(1); and an interference claim under the Family and Medical Leave Act (“FMLA”), 29 U.S.C. § 2601 et seq. (Docket No, 63). CSS’s Motion for Summary Judgment was granted as to all of Ms. Hawkins’ claims except for two: the retaliation claim and FMLA interference claim in regards to her 2013 termination. (Docket No. 103). At trial, Ms. Hawkins [901]*901argued that CSS retaliated against her for engaging in protected activity—the filing of this lawsuit—by firing her. She also claimed that CSS violated her right to return to her job, or an equivalent job, following her maternity leave and thereby violated her rights under the FMLA. CSS maintained that Ms. Hawkins was fired because her job duties were no longer necessary due to the implementation of the new computer system, Cemer.

After a four day trial, the jury returned a verdict in favor of Ms. Hawkins on her claim that she was terminated “in retaliation for engaging in protected activity under Title VII, § 1981, or the THRA[,]” (Docket No. 253). However, the jury found that Ms. Hawkins did not prove her FMLA interference claim. (Id.). Following the verdict, the jury awarded Ms. Hawkins $29,290.22 for back pay, $1 in compensatory damages, and $292,902.20 in punitive damages. (Id.). CSS then filed the pending motions.

ANALYSIS

I. Motions for Judgment as a Matter of Law

CSS has filed Renewed Motions for Judgment as a Matter of Law on the issues of Ms. Hawkins’ retaliation claim as well as punitive damages. (Docket Nos. 264 & 266). For the following reasons, both Motions for Judgment as a Matter of Law will be denied.

A. Legal Standard for Judgment as a Matter of Law

A renewed motion for judgment as a matter of law “may be granted only if in viewing the evidence in the light most favorable to the non-moving party, there is no genuine issue of material fact for the jury, and reasonable minds could come to but one conclusion, in favor of the moving party.” Arnold v. Wilder, 657 F.3d 353, 363 (6th Cir. 2011). “In entertaining a motion for judgment as a matter of law, the court is to review all evidence and draw all reasonable inferences in the light most favorable to the non-moving party, without making credibility determinations or weighing the evidence.” Jackson v. FedEx Corp. Servs., Inc., 518 F.3d 388, 392 (6th Cir. 2008) (citing Reeves v. Sanderson Plumbing Prod., Inc., 530 U.S. 133, 150-51, 120 S.Ct. 2097, 147 L.Ed.2d 105 (2000)). “In other words, the decision to grant judgment as a matter of law or to take the case away from the jury is appropriate “whenever there is a complete absence of pleading or proof on an issue material to the cause of action or when no disputed issues of fact exist such that reasonable minds would not differ.’” Id. (quoting Jackson v. Quanex Corp., 191 F.3d 647, 657 (6th Cir.1999)).

B. CSS’s Motion for Judgment as a Matter of Law on CSS’s Liability for Retaliation (Docket No. 264)

1. Legal Standard for Retaliation

In order to be successful on a retaliation claim, Ms. Hawkins needed to prove: (1) she engaged in activity protected by Title VII, 42 U.S.C. § 1981, or the THRA; (2) this protected activity was known to CSS; (3) CSS then took adverse employment action against Ms. Hawkins; and (4) there was a causal connection between the protected activity and the adverse employment action against Ms. Hawkins. See Morris v. Oldham Cty. Fiscal Court, 201 F.3d 784, 792 (6th Cir. 2000) (applying this framework to a Title VII retaliation claim); Noble v. Brinker Int’l, Inc., 391 F.3d 715, 720 (6th Cir. 2004) (“The elements of [a] prima facie case as well as the allocations of the burden of proof are the same for employment claims stemming from Title VII and § 1981.”); Newman v. Fed. Ex.

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247 F. Supp. 3d 897, 2017 WL 1131692, 2017 U.S. Dist. LEXIS 44330, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hawkins-v-center-for-spinal-surgery-tnmd-2017.