Patel v. Cook County Health & Hospital Systems

2024 IL App (1st) 230758-U
CourtAppellate Court of Illinois
DecidedJune 14, 2024
Docket1-23-0758
StatusUnpublished

This text of 2024 IL App (1st) 230758-U (Patel v. Cook County Health & Hospital Systems) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Patel v. Cook County Health & Hospital Systems, 2024 IL App (1st) 230758-U (Ill. Ct. App. 2024).

Opinion

2024 IL App (1st) 230758-U

No. 1-23-0758

Order filed June 14, 2024

FIFTH DIVISION

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1).

IN THE APPELLATE COURT OF ILLINOIS FIRST JUDICIAL DISTRICT

AEKTA PATEL, ) Appeal from the ) Circuit Court of Plaintiff-Appellant, ) Cook County. ) v. ) No. 20 L 9842 ) COOK COUNTY HEALTH AND HOSPITAL ) Honorable SYSTEMS (CCHHS), ) Mary Colleen Roberts, ) Judge, presiding. Defendant-Appellee. )

PRESIDING JUSTICE MITCHELL delivered the judgment of the court. Justice Lyle and Justice Navarro concurred in the judgment.

ORDER

¶1 Held: The circuit court’s order granting defendant’s motion for summary judgment is affirmed in part and reversed in part where there is a genuine issue of material fact regarding plaintiff’s claim under section 15 of the Whistleblower Act, but plaintiff’s claim under section 20 of the Act fails as a matter of law.

¶2 Plaintiff Aekta Patel appeals the circuit court’s order granting defendant Cook County

Health and Hospital Systems’ motion for summary judgment. The issue on appeal is whether the

circuit court erred in granting summary judgment. For the following reasons, we affirm in part and

reverse in part the circuit court’s order granting summary judgment and remand this case for

further proceedings. No. 1-23-0758

¶3 I. BACKGROUND

¶4 In 2009, plaintiff Aekta Patel was hired as an inpatient staff pharmacist by defendant Cook

County Health and Hospital Systems. Plaintiff was assigned to Cermak Health Services of Cook

County, the correctional health entity of CCHHS which provides onsite health care to detainees at

the Cook County Department of Corrections. One of the services Cermak provides to detainees is

an opioid treatment program. As part of the opioid treatment program, controlled narcotic

substances, suboxone and methadone, are used to help detainees reduce dependency on opioids.

Cermak pharmacists, including plaintiff, are responsible for dispensing these substances to

detainees. While defendant’s job descriptions for some of its nurse positions include the

administration of drugs to detainees, plaintiff’s job description did not require administering

suboxone and methadone to detainees, nor did defendant provide training to plaintiff regarding the

administration of suboxone and methadone.

¶5 Beginning in July 2018, plaintiff raised concerns to her supervisor, Dr. Mary Ann Wrobel,

that Cermak pharmacists were being required to orally administer suboxone and methadone to

detainees despite drug administration not being within the scope of the Pharmacy Practice Act

(225 ILCS 85/1 et seq. (West 2018)). Later that same month, plaintiff was disciplined for allegedly

being unprofessional on the phone with a county employee, which plaintiff alleges was a routine

instruction she gave to a medical technician about refill protocol. In August 2018, plaintiff emailed

CCHHS management and her pharmacist co-workers about a conversation she had with the Illinois

Department of Financial and Professional Regulations. Plaintiff claimed that the IDFPR

pharmacist license does not allow oral administration of controlled substances and that pharmacists

are only allowed to dispense, and not to administer, controlled substances. Throughout the next

-2- No. 1-23-0758

several months, plaintiff sent at least seven emails to CCHHS management regarding the

administration of suboxone and methadone at Cermak. In January of 2019, plaintiff received verbal

and written discipline for allegedly failing to follow orders from CCHHS management to stop

sending emails to management regarding her concerns about the administration of suboxone and

methadone by pharmacists.

¶6 During this same period of time, in addition to plaintiff’s internal complaints to CCHHS

management, plaintiff sent complaints to various outside agencies about Cermak pharmacists

being required to administer suboxone and methadone, including the IDFPR and the Illinois

Department of Human Services Division of Substance Use Prevention and Recovery (IDHS-

DSUPR). On October 17, 2018, the IDFPR investigated defendant’s work site and observed a

pharmacist “dispense and administer” suboxone and methadone to two detainees. (C 310.) After

the IDFPR visit, Dr. Wrobel informed plaintiff that the IDFPR had found nothing wrong. When

plaintiff asked for a report stating that the inspector had found nothing wrong, Dr. Wrobel stated

that plaintiff didn’t need it and walked away. On the same day as the IDFPR visit, plaintiff was

suspended for 13 days for allegedly violating HIPAA and “being insubordinate for failing to follow

a management directive.” (C 55.) The IDFPR performed a second visit in July 2019 and closed its

investigation in 2021. Additionally, the IDHS-DSUPR inspected defendant’s work site in January

2019, finding no violations under its jurisdiction.

¶7 In March of 2019, defendant terminated plaintiff’s employment, alleging that she had

violated HIPAA by scanning 83 documents containing patient protected health information onto

her Cook County email address. Plaintiff admitted that she had scanned the emails but argued that

she only scanned the patient records to her work email because she had been instructed by Dr.

-3- No. 1-23-0758

Wrobel to send plaintiff’s unfinished work to her supervisors, and that plaintiff had done this in

the past without it being considered a HIPAA violation. A hearing regarding these charges was

held, in which plaintiff contested the termination charges against her and made several requests,

including that defendant permanently remove suboxone and methadone administration from her

assigned tasks. In the hearing officer’s July 7, 2019, decision, he found that plaintiff had violated

HIPAA and five Cook County rules and regulations. However, the hearing officer found that

termination was too severe of a penalty and reduced plaintiff’s termination to a 29-day suspension.

¶8 On July 9, 2019, defendant sent plaintiff a letter requiring her to attend a mandatory

Employee Health Services return-to-work appointment on July 15. However, the letter was

postmarked on July 17 and plaintiff claimed that she did not receive the letter until that date, two

days after the scheduled return-to-work appointment. On July 31, defendant sent plaintiff a second

letter, noting that she had failed to attend the mandatory return-to-work appointment and that she

had fourteen business days from the receipt of the letter to contact the human resources department

regarding her return to work. Plaintiff received the letter on August 12.

¶9 On August 2, plaintiff’s attorney wrote a letter to defendant that reiterated plaintiff’s

previous request that administration of suboxone and methadone be permanently removed from

plaintiff’s assigned tasks at Cermak. Plaintiff did not otherwise contact defendant or the human

resources department, nor did defendant provide any response to plaintiff’s attorney’s letter. On

September 12, 2019, defendant terminated plaintiff’s employment for several stated reasons,

including job abandonment, gross insubordination, engaging in conduct that reflects adversely or

brings discredit to the CCHHS, and failure to follow instructions or failure to work in accordance

with CCHHS’s policies, procedures, and practices.

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Cite This Page — Counsel Stack

Bluebook (online)
2024 IL App (1st) 230758-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/patel-v-cook-county-health-hospital-systems-illappct-2024.