Ned v. Lafayette General Health System Inc

CourtDistrict Court, W.D. Louisiana
DecidedJanuary 21, 2022
Docket6:20-cv-00248
StatusUnknown

This text of Ned v. Lafayette General Health System Inc (Ned v. Lafayette General Health System Inc) is published on Counsel Stack Legal Research, covering District Court, W.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ned v. Lafayette General Health System Inc, (W.D. La. 2022).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAFAYETTE DIVISION

JACQUELINE NED CASE NO. 6:20-CV-00248

VERSUS JUDGE ROBERT R. SUMMERHAYS

LAFAYETTE GENERAL HEALTH MAGISTRATE JUDGE HANNA SYSTEM, INC.

MEMORANDUM RULING

The present matter before the Court is a Motion for Summary Judgment filed by Lafayette General Health Systems, Inc.1 For the reasons explained below, the Motion for Summary Judgment is GRANTED. I. BACKGROUND

Plaintiff Jacquelyn Ned asserts Title VII employment discrimination claims against defendant Lafayette General Health Systems, Inc. (“LGHS”). Ned, who is African American, alleges that she was subjected to racial harassment and discrimination, and that she was ultimately demoted as an RN Team Leader at St. Martin Hospital as a result of racial bias or animus.2 St. Martin Hospital is part of the LGHS system of health facilities. Ned was employed as a registered nurse at St. Martin Hospital on September 24, 2012.3 LGHS promoted Ned to the position of RN Team Leader on October 10, 2017.4 Ned contends that she received positive performance evaluations after her promotion.5 The summary judgment record includes Ned’s annual evaluation dated December 18, 2018, which appears to show a generally positive assessment of Ned’s

1 ECF No. 12. 2 ECF No. 1 at ¶¶ 32-36. 3 Id. at ¶ 7. 4 ECF No. 12-1 at 1. 5 ECF No. 16-5 at ¶¶ 3-5. performance as an RN Team Leader in 2018.6 The summary judgment record also includes a note to Ned from her supervisor, John Simar, commending her on her performance as an RN Team Leader: One of your co-workers shared with me how you are an effective team leader and that you remain calm in difficult situations and guide the staff to do the right thing for our patients. Also, you are instrumental in promoting teamwork. Thank you for your skills and professionalism.7

Ned states that she received this note on January 25, 2019.8 Simar was the Director of Nursing at St. Martin Hospital and served as Ned’s direct supervisor starting on September 1, 2018.9 The summary judgment record also reflects that Simar held at least three counseling sessions with Ned with respect to her performance as RN Team Leader beginning in February 2019.10 These counseling sessions addressed complaints against Ned by her co-workers, as well as concerns about Ned’s leadership abilities; they also addressed how she handled conflicts and confrontations with her colleagues.11 Specifically, on February 6, 2019, Ned met with Simar and Kia Butler, a member of LGHS’s Human Resources Department. At this meeting, Simar addressed confrontations between Ned and the staff she supervised. Simar’s notes of the meeting indicate that, in his view, Ned “personalizes issues which clouds her performance as a Team Leader and creates a negative experience.”12 Simar noted a specific confrontation between Ned and another staff member in which Ned angrily confronted that staff member. Simar observed that Ned “gets upset with someone and does not let it go.”13

6 ECF No. 16-4 at 1-5. The summary judgment record includes copies of additional reviews, but these reviews appear to cover a period after Ned’s demotion. 7 ECF No. 16-3. 8 ECF No. 16-5 at ¶4. 9 ECF No. 12-1 at 1; 12-3 at ¶¶ 2-3. 10 ECF No. 12-3 at 4-9. 11 Id. 12 Id. at 4. 13 Id. at 5. On March 12, 2019, Simar met with Ned again to discuss confrontations between Ned and her co-workers. According to Simar’s notes, Ned “immediately became defensive and angry.”14 Simar states that during the meeting Ned began to criticize the actions of the staff that she supervised.15 Simar notes that he did not see Ned as an effective Team Leader and “would like to remove her from this role.”16 On March 19, 2019, Ned was given a formal written warning on her

performance as a Team Leader.17 That written warning stated that Ned was counseled “on a least three (3) occasions regarding her behavior as the RN Team Leader, following multiple complaints regarding communication with staff and lack of conflict resolution.”18 Ned contends that before these counseling sessions in February and March 2019, she had never received any feedback or warnings about her poor performance as an RN Team Leader. Given her prior history of positive reviews, she contends that Simar was unfairly targeting her on account of her race by labeling her as a poor performer in February and March 2019. Ned states in her declaration that on March 12, 2019, she contacted Kia Butler “to report [Simar] as harassing and targeting me due to my race.”19 Ned also testified that after she received the March 19th written

warning, she provided a written “timeline of events” to the Chief Executive Officer of St. Martin Hospital, Karen Wyble.20 Ned contends that her complaints to Butler and Wyble were “dismissed as petty.”21 Kia Butler acknowledges in her declaration that Ned contacted her in March 2019 and relayed her conversations with Simar. However, Butler states that Ned “never complained of or mentioned that she was being harassed on the basis of her race.”22

14 Id. at 7. 15 Id. 16 Id. 17 ECF No. 12-3. 18 Id. 19 ECF No. 16-5 at ¶ 6. 20 Id. at ¶ 7. 21 Id. at ¶ 6. 22 ECF No. 19-2 at ¶ 7. Simar, Butler, and Wyble held additional meetings with Ned in June and July of 2019. On July 17, 2019, Wyble and Simar met with Ned. According to Wyble, Ned became angry and defensive and “started pointing her finger at” Wyble. Simar and Wyble requested that Ned “clock- out” for the shift because she had become “angry and accusatory” during the meeting.23 After this

meeting Wyble and Simar requested that LGHS’s Human Resources Department remove Ned from her position as RN Team Leader. At one point, Human Resources offered to move Ned to another LGHS facility, but Ned responded that she did not want to relocate.24 Ned was then placed on administrative leave for three weeks.25 LGHS ultimately demoted Ned back to the position of Staff RN.26 Ned then filed a complaint with the EEOC charging discrimination and harassment on the basis of race.27 Ned received a “Right to Sue Notice” from the EEOC on November 25, 2019.28 She filed the present action on February 24, 2020. In her Complaint, Ned asserts claims under Title VII. II. SUMMARY JUDGMENT STANDARD

Summary judgment is proper if the pleadings, discovery products on file, and affidavits show that there is no genuine dispute as to any material fact and that the movant is entitled to judgment as a matter of law.29 The purpose of summary judgment is to pierce the pleadings, to assess the proof, and to determine whether there is a genuine need for trial.30 Summary judgment

23 ECF No. 12-3 at 20. 24 ECF No. 16-5 at ¶¶ 11-12. 25 ECF 12-3 at ¶ 13. 26 ECF No. 12-1 at ¶¶ 10-11. 27 ECF No. 1 at ¶ 27. 28 ECF No. 1 at ¶ 27. 29 Fed. R. Civ. P. 56(a). 30 See Matsushita Electric Industries v. Zenith Radio Corp. 475 U.S. 574, 587, 106 S. Ct. 1348, 89 L.Ed.2d 538 (1986). procedure is designed to isolate and dispose of factually unsupported claims or defenses.31 If the movant bears the burden of persuasion at trial on a claim or defense addressed in the motion for summary judgment, the movant must establish that there is no genuine dispute of material fact as to those claims or defenses. To satisfy this burden, the movant must come forward with competent

summary judgment evidence conclusively establishing that no reasonable trier of fact could find other than for the moving party.32 To avoid summary judgment, the non-movant must then come forward with evidence showing that there is a genuine dispute of material fact.

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Ned v. Lafayette General Health System Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ned-v-lafayette-general-health-system-inc-lawd-2022.