Margaret MacGlashan v. Abs Lincs Ky, Inc. D/B/A Cumberland Hall Hospital

CourtKentucky Supreme Court
DecidedJanuary 14, 2015
Docket2014 SC 000098
StatusUnknown

This text of Margaret MacGlashan v. Abs Lincs Ky, Inc. D/B/A Cumberland Hall Hospital (Margaret MacGlashan v. Abs Lincs Ky, Inc. D/B/A Cumberland Hall Hospital) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Margaret MacGlashan v. Abs Lincs Ky, Inc. D/B/A Cumberland Hall Hospital, (Ky. 2015).

Opinion

RENDERED: DECEMBER 18, 2014 TO BE PUBLISHED

supreme (Eourf of 1,firuluth 2014-SC-000098-CL

IN RE:

MARGARET MACGLASHAN DATE 1-s t 15 1-X.,"A

UNITED STATES DISTRICT COURT V. WESTERN DISTRICT OF KENTUCKY, PADUCAH DIVISION CIVIL ACTION NO. 5:13-CV-00135-TBR

ABS LINCS KY, INC. D/B/A CUMBERLAND HALL HOSPITAL

OPINION OF THE COURT BY JUSTICE VENTERS

CERTIFYING THE LAW

Pursuant to CR 76.37(1), this Court granted the certification request of

The United States District Court for the Western District of Kentucky to answer

the following question of Kentucky law:

Can a plaintiff who alleges that her employment was wrongfully terminated in violation of Kentucky Revised Statute 216B.165 assert a claim for the recovery of front pay, along with other damages she may have sustained, by reason of her discharge?

For the reasons stated below, we conclude that the answer is "yes."

I. FACTUAL AND STATUTORY BACKGROUND

Because the case comes to this Court upon a Certification Order

requested by the United States District Court, we review the question presented upon a limited but adequate factual record. According to the

Certification Order, Margaret Macglashan alleges in her suit in the federal

district court that she had been employed by ABS LINCS, KY., doing business

as Cumberland Hall Hospital, and that she was fired because she was

"preparing to report a clear medication error" to an appropriate hospital

regulatory authority pursuant to KRS Chapter 216B.

KRS Chapter 216B broadly covers the regulation of health care facilities

and services in Kentucky. KRS 216B.165(1) requires hospital employees to

report circumstances in which "patient safety" or "quality of care" is "in

jeopardy." KRS 216B.165(3) provides a kind of whistle-blower protection for

health facility workers. It prohibits a health care facility or service from

retaliating against an employee who reports any deficiencies of the facility or

service pursuant to KRS 216B.165(1). However, KRS Chapter 216B does not

prescribe any specific civil remedies for the whistle-blowing employee who

suffers retaliation for making such a report. For remedies, one must look to

the generic provisions of KRS 446.070 which states: "A person injured by the

violation of any statute may recover from the offender such damages as he

sustained by reason of the violation, although a penalty or forfeiture is imposed

for such violation."

II. ANALYSIS: FRONT PAY, KRS 2168.165(3), AND KRS 446.070

In the parlance of wrongful termination of employment litigation, "front

pay" is "money awarded for lost compensation during the period between

judgment and reinstatement or in lieu of reinstatement." Pollard v. E.I. du Pont

2 de Nemours & Co., 532 U.S. 843, 846 (2001). See also Brooks v. Lexington-

Fayette Urban County. Hous. Auth., 132 S.W.3d 790, 806 (Ky. 2004). As

opposed to front pay, "back pay" or "lost wages" includes the damages incurred

from the date of the wrongful termination until the date the matter is

adjudicated. Front pay is awarded for compensation lost during the period

between the date of the adjudication and the reinstatement of employment, or

where reinstatement is not an appropriate remedy,' the date of re-employment

by another employer in lieu of reinstatement. Thus, front pay is just as much

of a "damage sustained" as back pay; the principal difference between the two

is that back pay represents lost wages incurred before the trial and front pay

represents a reasonable estimate of damages that will accrue after the trial.

See Dollar Gen. Partners v. Upchurch, 214 S.W.3d 910, 918 (Ky. App. 2006).

"The purpose of front pay is limited to compensating the employee for wages

lost as a result of the wrongful termination." Id. at 921.

The issue essentially boils down to whether front pay fits within the

statutory language of KRS 446.070 permitting a plaintiff to recover "such

damages as he sustained by reason of the violation." The answer is obvious —

"lost compensation during the period between judgment and reinstatement or

in lieu of reinstatement" is a "damage[] sustained by reason of the violation." A

loss of income extending after the date of the adjudication is a type of injury

'Reinstatement may not be an appropriate remedy in some cases because the whistleblower litigation may have so damaged the relationship between the whistleblower and other employees of the establishment that a congenial ongoing work atmosphere may be impractical.

3 that one might reasonably be expected to suffer as a result of a wrongful

discharge in violation of KRS 216B.165(3).

An employee acting under the protection of KRS 216B.165(3) could not

be made whole without front pay, since the measure of his or her damages

would necessarily include those wages lost between the time of the judgment

and the time of reinstatement (or some remuneration that reasonably

compensates the employee in lieu of reinstatement). If not for the wrongful

reprisal by the employer, the employee would have collected her wages during

that time frame and, therefore, the wrongful loss of those wages is

compensable as damages in a civil action because the loss represents a

"damage[] sustained by reason of the violation." If, as noted in Pollard, front

pay is "compensation for wages lost," it is obviously a monetary damage

foreseeably suffered by one who was wrongfully fired.

The argument proffered against allowing an award of front pay is based

upon a flawed syllogism. First, the Hospital points out that our decision in

Pari-Mutuel Clerks' Union of Kentucky, Local 541, SEIU, AFL-CIO v. Kentucky

Jockey Club, 551 S.W.2d 801, 802 (Ky. 1977) holds that KRS 446.070 does not

provide a right of reinstatement for wrongful termination because

reinstatement is an equitable remedy rather than a kind of "damage[]

sustained." Next, it cites to our holding in Brooks that "front pay either

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Related

Pollard v. E. I. Du Pont De Nemours & Co.
532 U.S. 843 (Supreme Court, 2001)
Dollar General Partners v. Upchurch
214 S.W.3d 910 (Court of Appeals of Kentucky, 2006)
Brooks v. Lexington-Fayette Urban County Housing Authority
132 S.W.3d 790 (Kentucky Supreme Court, 2004)
Aetna Casualty & Surety Co. v. Commonwealth
179 S.W.3d 830 (Kentucky Supreme Court, 2006)
Ferry v. Cundiff Steel Erectors, Inc.
218 S.W.3d 390 (Court of Appeals of Kentucky, 2006)

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Margaret MacGlashan v. Abs Lincs Ky, Inc. D/B/A Cumberland Hall Hospital, Counsel Stack Legal Research, https://law.counselstack.com/opinion/margaret-macglashan-v-abs-lincs-ky-inc-dba-cumberl-ky-2015.