Jillian Crabtree, V. Jefferson County Public Hospital District 2

CourtCourt of Appeals of Washington
DecidedDecember 14, 2021
Docket54951-4
StatusPublished

This text of Jillian Crabtree, V. Jefferson County Public Hospital District 2 (Jillian Crabtree, V. Jefferson County Public Hospital District 2) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jillian Crabtree, V. Jefferson County Public Hospital District 2, (Wash. Ct. App. 2021).

Opinion

Filed Washington State Court of Appeals Division Two

December 14, 2021

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II

JILLIAN CRABTREE, No. 54951-4-II

Appellant,

v. PUBLISHED OPINION

JEFFERSON COUNTY PUBLIC HOSPITAL DISTRICT NO. 2 d/b/a JEFFERSON HEALTHCARE,

Respondent.

WORSWICK, J. — Jillian Crabtree appeals the trial court’s order granting summary

judgment dismissing her claims of sex discrimination against her employer, Jefferson

Healthcare. Jefferson Healthcare fired Crabtree after she became pregnant. On appeal, Crabtree

argues that there is a genuine issue of material fact as to whether (1) Jefferson Healthcare’s

stated reasons for her termination were a pretext for discrimination, and (2) Jefferson Healthcare

was substantially motivated by Crabtree’s pregnancy when it made the decision to discharge her.

Because issues of material fact exist regarding both these issues, we reverse the order

granting summary judgment and remand for further proceedings.

FACTS

I. BACKGROUND ON CRABTREE’S POSITION

Crabtree started working at Jefferson Healthcare as the manager of patient access services

in May 2018. Crabtree’s direct supervisor was Jennifer Goodwin, who was in turn supervised by

Hilary Whittington. Crabtree’s job duties included overseeing three registration desks: one at the

main entrance of the hospital, one at the emergency department, and another at the “walk-in” No. 54951-4-II

clinic. Crabtree supervised up to 20 employees at a time and managed those employees’ hours,

schedules, and personnel issues. Crabtree’s position required her to have working knowledge of

the electronic medical record (EMR) system and an understanding of the financial counselors’

role in order to assist her team should an issue arise.

Every other week, Crabtree had regular one-on-one meetings with Goodwin and Allison

Crispen, a human resources (HR) “business partner,” who was assigned to assist Crabtree in all

HR and policy matters. Crabtree described the purpose of those meetings as an open

conversation and an opportunity to receive advice and input.

II. CRABTREE’S PERFORMANCE EVALUATION

About seven months after Crabtree started her position, she received her first

performance evaluation on November 26, 2018. The evaluation included a self-assessment

section, followed by the supervisor’s assessment on a scale of 1-4, with 4 being the highest

score.1 The evaluation contained a total of 19 values, divided across four categories. The

categories and values were as follows:

(1) “Organizational Values,” included “Compassion, Respect, Teamwork, and Stewardship;” (2) “Organizational Competencies,” included “Professional Practices, Quality and Safety, Service, Effective Decision Making, Communication, Initiative, and Accountability;” (3) “Position Standards” included “Overall Job Knowledge, Operations and Policy/Procedures, Productivity/Efficiency;” and, (4) “Leadership Skills” included “Quality and Safety, People, Service, Community Health, and Sustainability.”

CP at 580-83.

1 “1” is defined as “does not meet expectations,” “2” is defined as “needs improvement,” “3” is defined as “meets expectations,” and “4” is defined as “exceed expectations.” CP at 580.

2 No. 54951-4-II

For category (1), Goodwin awarded Crabtree a “3,” meaning that she met expectations

for all the listed values. For category (2), Goodwin awarded Crabtree a “3” in all values, except

for “effective decision making,” to which she rated Crabtree a “2,” meaning she needed

improvement. Goodwin included written feedback for category (2). Her feedback stated:

As we’ve discussed in our vision for the front end, this is one of your priorities and areas where you and the team can gain energy around this forward direction. Creating an environment where our team has actively thought [through] what our patients’ needs are, prior to them presenting on their date of service, is where our operational planning should be.

CP at 581. Under category (3), Goodwin rated Crabtree’s performance as a “2,” needing

improvement, on two of three values: “overall job knowledge” and “productivity and efficiency.”

Goodwin included written feedback for category (2):

Patient Access scope is at the core of ensuring an accurate, efficient and streamlined revenue cycle stream. I encourage you to utilize both NAHAM information/ networking and HBI tools/best practice materials as great references for Patient Access knowledge and understanding.[2]

CP at 582.

In category (4), “Leadership Skills,” Goodwin rated Crabtree’s performance as a “3,”

meeting expectations, in all values, except for a value labeled as “people,” for which Goodwin

awarded Crabtree a “2,” needing improvement. “People” is defined as:

Actively works toward recruiting and retaining a high performing workforce; builds and maintains strong provider/dyad relationships. Achieves top quartile results in the employee engagement survey. Seeks out current and constructive feedback and able to respond/adapt to feedback given; holds self and peers accountable to the standards of the organization. Engages and develops team.

CP at 583. In the written feedback that followed, Goodwin expressed the following:

2 “NAHAM” and “HBI” are not defined in the record on appeal.

3 No. 54951-4-II

[I]t often becomes a balancing act of listening and being available and ensuring that [your team] understand[s] there is structure in place to share their feedback in a professional and respectful manner. I think they are on a learning curve, as you are, with building trust with a new leader and “feeling out” what you will allow with their conduct. I’ve seen you get stronger over the last month of backing up your responses with both HR assistance and policy and procedures to show the context of your direction. Keep up this rhythm and partnership with HR as you continue to set structure and expectations for the team . . . The team will need to see that there is reasoning, structure and methodology behind the changes from their Leader.

CP at 584. At the end of the evaluation, Goodwin noted that Crabtree was doing “nice work,”

and that she was “impressed” with Crabtree’s “professional self-reflection,” which she noted was

“admirable and a great leadership skill.” CP at 586.

Goodwin also included a summary of areas where Crabtree could improve. The

summary included: (1) improving Crabtree’s understanding of registration and financial

counseling and its impact on “overall revenue cycle steam,” (2) exploring “what works for

communication” with Crabtree’s team, and (3) increasing visibility with the registration team

and allowing for more in person discussions to “resolve issues in the moment.” CP at 586. In

total, Goodwin rated Crabtree as “meeting expectations” in 12 out of 16 categories.3

Following the evaluation, Whittington included a two-page letter to Crabtree, which was

“highly unusual” for her to do. CP at 375. In the letter, Whittington told Crabtree that she had a

“good first year” and that she had “done a nice job stepping into an entirely new career.” CP at

588-89. She also offered additional feedback.

Regarding scheduling and staffing, Whittington was “excited” for Crabtree to

“challenge” the status quo with scheduling and staffing. CP at 588. Whittington also asked

3 In total, the evaluation has 19 values, but Goodwin only included a rating for 16 of those values.

4 No. 54951-4-II

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Jillian Crabtree, V. Jefferson County Public Hospital District 2, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jillian-crabtree-v-jefferson-county-public-hospital-district-2-washctapp-2021.