Maloney v. Mainegeneral, Health, Inc.

CourtSuperior Court of Maine
DecidedFebruary 18, 2014
DocketKENcv-13-5
StatusUnpublished

This text of Maloney v. Mainegeneral, Health, Inc. (Maloney v. Mainegeneral, Health, Inc.) 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
Maloney v. Mainegeneral, Health, Inc., (Me. Super. Ct. 2014).

Opinion

STATE OF MAINE SUPERIOR COURT KENNEBEC, ss Location: Augusta Docket No.: CV-13-~ /_, /, A'JMM- Kuj --~;c£(11-f ) KELLEY MALONEY, ) ) Plaintiff, ) ) V. ) ORDER ON MOTION FOR SUMMARY ) JUDGMENT MAINEGENERAL, HEALTH, INC., ) ) Defendant ) )

Before the Court is the motion for summary judgment of Defendant MaineGeneral

Health, Inc. (MGH) on the sole count of Plaintiff Kelley Maloney's complaint: employment

discrimination in violation of the Maine Human Rights Act (MHRA), 5 M.R.S. §§ 4551-4634

(2013). Maloney is an operating room (OR) nurse who has a latex allergy. Maloney alleges

that MGH failed to reasonably accommodate her disability by not providing her with an

environment free of latex gloves. 1 Because issues of material fact remain that must be resolved

by a fact finder, the Court must deny the motion for summary judgment.

FACTUAL BACKGROUND

The following facts are undisputed except where noted. See DeCambra v. Carson, 2008

ME 127, ~ 2, 953 A.2d 1163.

Plainti.ff's hiring at MGH. MGH hired Maloney as a surgical technician in the OR

effective December 28, 2010. During her pre-employment physical, Maloney disclosed a

1 MGH's motion at some points refers to Maloney's need for a completely latex free environment, as that was Maloney's _doctor's recommendation after her departure from MGH. One ofMGH's arguments in support of summary JUdgment asserts that a latex free environment is not possible and thus not a reasonable accommodat~on. (MSJ 15-16.) Nevertheless, the claim as stated in Maloney's complaint only is related to not accommodatmg Maloney by providing an environme t fr fI 1 I I

accommodate based on a completely latex free enviro~e;; i~ m~~;~a~;d~es, and any argument about fathng to sensitivity to latex but did not state she had any respiratory Issues from latex exposure.

Maloney requested that MGH provide her with latex-free surgical gloves and a hypoallergenic

mask upon hire.

MGH's use of latex gloves. MGH did not use powdered latex gloves; the majority of

MGH OR staff used latex-safe gloves, i.e., powder-free, low-protein surgical gloves containing

latex. 2 MGH made latex-free gloves available to anyone who wanted to use them, and required

their use with patients allergic or sensitive to latex.

Plainti.ff's asthma attacks. MGH did not provide Maloney with a hypoallergenic mask at

first. Instead, MGH asked her to try on of their stocked masks first. Maloney experienced an

asthma attack after about 10 minutes of wearing one of the stocked masks, which did not

contain latex; thereafter, MGH ordered hypoallergenic masks for Maloney.

On January 14, 2011, approximately a week after she began working in the OR,

Maloney was helping a surgeon put on latex-safe gloves when she experienced an asthma

attack. 3 Maloney herself was wearing a hypoallergenic mask and latex-free gloves. Maloney

left the OR and utilized her inhalers to quell the attack.

Plainti.ff's subsequent diagnosis and requested accommodation. Maloney saw Dr. Kenneth

McKenzie at MGH's Workplace Health office on the same day of her attack. Dr. McKenzie

diagnosed Maloney with irritant bronchitis related to aerosolized latex exposure and

recommended she be removed from any exposure to aerosolized latex, but noted there were no

objective allergy tests done. MGH found work for Maloney outside the OR until she could be

seen by her own doctor. 4

2 Maloney objects as to foundation, without any explanation, but otherwise admits this statement of material fact. 3 Maloney denies this statement, but the denial goes only to when Maloney learned that the gloves were latex- safe. 4 Maloney objects to a portion of this statement of material fact not included within the Court's recitation of facts.

2 On January 20, 2011, Maloney saw her primary care physician, Dr. Daniel Gott. Dr.

Gott concluded the asthma attack was connected to exposure to the surgeon's gloves because of

the timing, Maloney's known sensitivity to latex, and lack of other asthma inducing triggers.

Dr. Gott wrote a note to MGH on behalf of Maloney that stated Maloney "may return to work

in the operating room however needs to have an environment free of latex gloves which is really

standard of care in modern hospitals today due to the high prevalence of latex allergy in

healthcare workers." When MGH sought clarification, Dr. Gott stated that Maloney should

not be in an OR when those scrubbed in for surgery were using latex gloves. There is a dispute

over whether Dr. Gott knew that MGH was utilizing latex-safe gloves when he gave this

diagnosis/opinion, and thus whether his diagnosis was sufficient to substantiate Maloney's need

for accommodation.

MGH, for its part, questioned whether Maloney had reacted to latex-safe gloves, and if

she had, also questioned whether the elimination of latex gloves alone would be sufficient

accommodation because of other sources of latex. Accordingly, MGH asked Maloney to

undergo allergy testing at her own expense. Maloney consulted with Dr. Gott before

undergoing allergy testing, but what Dr. Gott said and recommended is a matter of dispute.

Maloney told MGH she would undergo the testing ifMGH paid for it, but at this time, MGH

would not pay for the testing. Maloney chose not to undergo allergy testing.

MGH's investigation into the requested accommodation and determination on requested

accommodation. In investigating Maloney's requested accommodation, MGH polled 21

surgeons regarding switching to latex-free gloves in the OR. Generally, the surgeons did not

wish to use latex-free over latex-safe gloves because the fit and tactile sensation was better in

latex-safe gloves, and expressed barrier concerns over switching to latex-free. 5 MGH

5 Maloney objects that these statements are hearsay but otherwise admits the statements of material facts.

3 determined it could not reasonably make the OR an "environment free of latex gloves" as

recommended by Dr. Gott, although Maloney notes his recommendation applied only to times

when she was present in the OR.

MGH informed Maloney that they could not reasonably accommodate the restriction

recommended by Dr. Gott in the OR, but would work to find her another position in the system

where she would not be exposed to latex gloves. The parties dispute whether Maloney was

offered another position, or if she had to apply for another open position within the hospital. As

alternative reasonable accommodations, Maloney suggested that she wear a "Stryker hood" for

surgery, and that the OR need only be free of latex gloves when she was scrubbing in.

Ultimately, Maloney's employment at MGH ceased on February 18, 2011, and she later began

work at Inland Hospital.

Offer of reinstatement. The parties agree that MGH made an unconditional offer of

reinstatement to Maloney on November 9, 2011. The offer was for her previous position, but

now with the requested accommodation: an environment free of latex gloves. Maloney did not

respond until December 5, 2011. At that time, Maloney informed MGH through counsel that

four weeks prior she had had an adverse reaction to a latex foley catheter. Maloney was trying

to schedule an appointment with Dr. Gott to get his recommendations on any further

accommodations needed and could not respond to the offer until she did so. Maloney was also

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