Janice Hamilton v. Louisville & Jefferson County Metropolitan Sewer District

CourtCourt of Appeals of Kentucky
DecidedFebruary 29, 2024
Docket2023 CA 000225
StatusUnknown

This text of Janice Hamilton v. Louisville & Jefferson County Metropolitan Sewer District (Janice Hamilton v. Louisville & Jefferson County Metropolitan Sewer District) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Janice Hamilton v. Louisville & Jefferson County Metropolitan Sewer District, (Ky. Ct. App. 2024).

Opinion

RENDERED: MARCH 1, 2024; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2023-CA-0225-MR

JANICE HAMILTON APPELLANT

APPEAL FROM JEFFERSON CIRCUIT COURT v. HONORABLE ANNIE O’CONNELL, JUDGE ACTION NO. 20-CI-006304

LOUISVILLE & JEFFERSON COUNTY METROPOLITAN SEWER DISTRICT APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: ACREE, GOODWINE, AND JONES, JUDGES.

GOODWINE, JUDGE: Janice Hamilton (“Hamilton”) appeals from the October

6, 2022 and January 30, 2023 judgments of the Jefferson Circuit Court. After

careful review and consideration of the parties’ oral arguments, we affirm.

BACKGROUND

Hamilton began employment with the Louisville and Jefferson County

Metropolitan Sewer District (“MSD”) in 2011. She worked as a member of a field crew doing maintenance, repairs, and construction. She began as a Utility Trainee

before advancing to the position of Utility Worker I and then to Utility Worker II.

On February 10, 2012, Hamilton injured her ankle on the job and

subsequently filed a workers’ compensation claim. After being temporarily

restricted from working, she returned to her position. She was injured on the job

for a second time on August 1, 2014. She again filed a workers’ compensation

claim and she was again able to return to her position on the field crew.

In 2015, Hamilton applied for a position in the MSD dispatch

department. After failing the requisite typing test once, she passed it and was

transferred on February 6, 2016. She was supervised by Yvonne Austin

(“Austin”). Hamilton admits she struggled with the duties of her new position,

especially because the work required use of computers. She acknowledges she did

not meet the expectations of the position. Her performance reviews showed that

she needed additional attention and training, and her inability to perform her duties

created additional work for other staff. Her evaluations also show she reacted

poorly to feedback and her behavior negatively impacted her peers.

Austin and Hamilton had a contentious working relationship.

Hamilton alleges various acts of harassment, including micromanagement and rude

remarks from Austin. In 2016, a few months after she began working for dispatch,

Hamilton filed a human resources (“HR”) complaint alleging Austin provided her

-2- insufficient training and claimed Austin created a stressful work environment by

criticizing her performance in front of other staff. Hamilton did not claim she was

disabled or that the alleged harassment was based on a disability. HR investigated

the allegations, and they were unsubstantiated.

In February 2018, Austin placed Hamilton on a 90-day performance

improvement plan (“PIP”). The PIP detailed the skills and duties in which

Hamilton needed to improve to meet the expectations for her position. Hamilton

failed to complete the PIP. Her evaluations continued to show she had not

improved and was rude to other staff. According to an evaluation completed after

the PIP, she did not “possess the capabilities to function in her current position.”

Record (“R.”) at 308.

On June 6, 2018, Austin instructed Hamilton to take her scheduled

lunch break. Hamilton repeatedly refused to do so. According to witnesses and

Hamilton’s admission, in response to Austin’s instruction, she yelled, “I’m sick of

you.” Id. at 319. The next day, Angela Basil (“Basil”), an MSD Employee

Relations Administrator, met with Hamilton and gave her a one-day suspension

without pay because her behavior violated MSD’s rules of conduct. Hamilton

alleged Austin’s instruction for her to take her lunch break was harassment. HR

determined Austin’s instruction was reasonable and Hamilton should have

-3- communicated with her supervisor in a respectful manner. Austin was not

disciplined for the incident.

In September 2018, Hamilton informed HR that she would need to

move around during her shifts because she was at risk of developing cramps or

blood clots. Hamilton is diabetic though she did not mention her diagnosis on her

request form. On that form, her medical provider stated Hamilton experienced

neuropathy which can be aggravated by “prolonged periods of sitting.” Id. at 327.

Her provider recommended she be allowed to walk around for five minutes every

one to two hours. Id. at 328. Hamilton was permitted to take additional breaks as

needed.

In October 2018, Hamilton filed a second HR complaint against

Austin. She alleged Austin followed her to the restroom and harassed her about

taking too long. She admits she was making a personal phone call from the

restroom. She again makes no mention of any alleged disability in her complaint.

HR investigated the incident and found it unsubstantiated.

In January 2019, Hamilton acknowledged she “dropped the ball” by

failing to properly follow up on a request that led to significant sewage backup in a

customer’s yard. Id. at 333. She met with HR and was given a five-day

suspension without pay for the error. A week later, she applied for and received a

leave of absence under the Family and Medical Leave Act (“FMLA”) for an

-4- “unspecified anxiety disorder.” Id. at 341. She sought treatment at The Brook.

Her provider recommended an “intensive outpatient treatment program.” Id. In a

letter, her provider recommended she transfer back to a job in the field. Hamilton

was discharged from The Brook and cleared to return to work in June 2019.

Neither Austin nor Basil were informed of the reason for Hamilton’s leave of

absence.

Thereafter, Hamilton requested an accommodation based on her

provider’s recommendation to “return to work out in the field.” Id. at 343. Based

on documentation from The Brook, MSD allowed Hamilton to transfer back to a

field position. She began work as a Utility Trainee on July 13, 2019.1 Hamilton

continued to work in field positions with MSD until early 2021. In February 2021,

she was injured again and filed a third workers’ compensation claim. She did not

return to work at MSD after this injury.

On October 30, 2020, while she was still employed by MSD,

Hamilton filed a complaint in Jefferson Circuit Court alleging disability

discrimination, hostile work environment, workers’ compensation retaliation, and

1 In this position, Hamilton was a member of the Laborers International Union of North America (“LIUNA”). Under the union’s collective bargaining agreement’s seniority rules, she was required to transfer back to a trainee position. After the 30-day probationary period, she progressed back to the position of Utility Worker II. The agreement also governed the way LIUNA members were able to change shifts based on seniority. R. at 346.

-5- negligent infliction of emotional distress (“NIED”). Thereafter, MSD moved for

summary judgment on Hamilton’s claims.

In its October 6, 2022 judgment, the trial court granted summary

judgment on all claims except the NIED claim. The court determined there

remained genuine issues of material fact as to Hamilton’s NIED claim. Thereafter,

MSD again moved for summary judgment on Hamilton’s remaining claim. On

January 30, 2023, the court granted summary judgment. Relying on Johnson v.

Pennyrile Allied Community Services, No. 5:20-CV-071-TBR, 2022 WL 1004873

(W.D. Ky. Apr. 4, 2022), the trial court held Hamilton’s NIED claim was

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Janice Hamilton v. Louisville & Jefferson County Metropolitan Sewer District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/janice-hamilton-v-louisville-jefferson-county-metropolitan-sewer-kyctapp-2024.