Miller v. E. Maine Med. Ctr.

CourtSuperior Court of Maine
DecidedMarch 16, 2009
DocketPENcv-07-285
StatusUnpublished

This text of Miller v. E. Maine Med. Ctr. (Miller v. E. Maine Med. Ctr.) 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
Miller v. E. Maine Med. Ctr., (Me. Super. Ct. 2009).

Opinion

STATE OF MAINE SUPERIOR COURT PENOBSCOT, ss. CIVIL ACTION DOCKET NO. CV-07-285 , I' - ~.-J/ '-"'"

ELIZABETH MILLER,

Plaintiff,

v. ORDER

EASTERN MAINE MEDICAL FILED &ENTERED CENTER, SUPERIOR COURT Defendant. MAR 16 2009 PENOBSCOT COUNTY This case is before the Court on a motion for summary judgment filed on July 1,

2008 by the defendant, Eastern Maine Medical Center ("EMMC"). EMMC filed a

second motion for summary judgment on October 31, 2008. Oral argument was held on

the first motion on December 2, 2008.

BACKGROUND

The plaintiff, Elizabeth Miller, was previously employed at EMMC as an EEG

technologist in the EEG Department, which was supervised by Patrick O'Leary. Kelli

Veilleux, Christina Cobane, and Terrance Rooney, all EEG technologists, also worked in

the department along with Emily Prescott, the department's receptionist.

The facts of the situation, viewed in a light most favorable to the plaintiff, are as

follows. Miller and her co-workers suspected a sexual relationship between O'Leary and

Cobane. O'Leary also favored Cobane by giving her preferential work assignments, by

refusing to discipline her for lying about her reasons for missing work and speaking

rudely towards other in the department, and in determining work and vacation schedules

among those in the department. Cobane and O'Leary also took part in banter of a sexual

1 nature at the workplace and spent hours of time alone together in O'Leary's office.

Specifically the two would tell sexual jokes, talk openly about each others' sex lives, and

make comments regarding women passing by.

Miller confronted O'Leary on January 7, 2007 regarding the perceived favoritism

towards Cobane. Miller suggested that they involve EMMC's Human Resources

Department to help resolve the issues. O'Leary thanked Miller for bringing her concerns

to him and stated that the issue could be resolved at a staff meeting. The next day Miller

met with Paul Bolin, EMMC's Director of Employee Relations. Miller expressed to

Bolin concerns about O'Leary's management of the department, particularly relating to

his failure to address problems with Cobane. Miller also asked Bolin that she be granted

a leave of absence because of fears regarding retaliation from O'Leary. Bolin assured her

that retaliation would not be tolerated.

Miller returned to work. In the week following Miller's meetings with O'Leary

and Bolin, Cobane again missed work and lied about being sick. Then, on January 17,

2007, Cobane was to receive an award for having previously arranged a conference,

having been recommended for the award by O'Leary. Miller was so upset regarding

Cobane's receipt of the award she went home sick. Subsequently, Miller consulted an

attorney, took an unpaid leave of absence, and eventually resigned from her employment

atEMMC.

DISCUSSION

A. Standard of Review

"Summary judgment is appropriate when review of the parties' statements of

material facts and the referenced record evidence indicates no genuine issue of material

2 fact that is in dispute, and, accordingly, the moving party is entitled to judgment as a

matter of law." Dyer v. Dep't of Transp., 2008 ME 106, ~ 14, 951 A.2d 821, 825. A

genuine issue of material fact exists when there is sufficient evidence to require the fact-

finder to choose between competing versions of a fact that could affect the outcome of

the case. Id. at 825; Inkel v. Livingston, 2005 ME 42, ~ 4, 869 A.2d 745, 747.

B. Count I - Sexual Harassment

At the center of the Miller's claim is an alleged relationship between Patrick

O'Leary and Christina Cobane. The record shows that employees in the department

suspected that the two may have had a sexual relationship. Miller and others in the

department also observed what appeared to be preferential treatment by O'Leary towards

Cobane. Miller claims that O'Leary's alleged relationship with and preferential treatment

towards Cobane created an "implicit 'quid pro quo'" and a hostile work environment by

sending "a message that the way for women to get ahead in the workplace is by engaging

in sexual conduct." EEOC Notice No. 915-048 (Jan. 12, 1990).

Such preferential treatment, while potentially upsetting to Miller, is not

actionable. The law "does not prohibit favoritism shown to a. supervisor's paramour

because such preferential treatment is based on voluntary romantic affiliation and not

gender differences." Miller v. Regents of the Univ. of Colorado, 1999 U.S. App. LEXIS

16712, at *21 (lOth Cir. 1999). The United States Equal Opportunity Commission Policy

Guidance on Employer Liability under Title VII for Sexual Favoritism, which Miller

relies on, provides:

Not all types of sexual favoritism violate Title VII. It is the Commission's position that Title VII does not prohibit isolated instances of preferential treatment based upon consensual romantic relationships. An isolated instance of favoritism toward a "paramour" (or a spouse, or a friend) may

3 be unfair, but it does not discriminate against women or men in violation of Title VII, since both are disadvantaged for reasons other than their genders. A female charging party who is denied an employment benefit because of such sexual favoritism would not have been treated more favorably had she been a man nor, conversely, was she treated less favorably because she was a woman.

EEOC Notice No. 915-048 (Jan. 12,1990) (footnotes omitted).l In fact Miller not only

complains that she was disadvantaged because of O'Leary's alleged favoritism towards

Cobane, but she also complains that her male coworker, Terrance Rooney, suffered

similarly.

It is clear froni the EEOC guidelines and all of the federal cases on this issue that

a plaintiff cannot recover for sexual harassment based upon a supervisor's preferential

1 The EEOC Policy Guidance on Employer Liability under Title VII for Sexual Favoritism also offers the following two examples.

Example I - Charging Party (CP) alleges that she lost a promotion for which she was qualified because the co-worker who obtained the promotion was engaged in a sexual relationship with their supervisor. EEOC's investigation discloses that the relationship at issue was consensual and that the supervisor had never subjected CP's co-worker or any other employees to unwelcome sexual advances. The Commission would find no violation of Title VII in these circumstances, because men and women were equally disadvantaged by the supervisor's conduct for reasons other than their genders.

Even if CP is genuinely offended by the supervisor's conduct, she has no Title VII claim.

Example 3 - Same as Example I, except CP's supervisor and other management personnel regularly solicited sexual favors from subordinate employees and offered job opportunities to those who complied. Some of those employees willingly consented to the sexual requests and in turn received promotions and awards. Others consented because they recognized that their opportunities for advancement wou ld otherwise be limited. CP, who did not welcome this conduct, was not approached for sexual favors. However, she and other female and male coworkers may be able to establish that the conduct created a hostile work environment.

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