Sankranthi v. El Camino Hospital CA6

CourtCalifornia Court of Appeal
DecidedMarch 8, 2024
DocketH049506
StatusUnpublished

This text of Sankranthi v. El Camino Hospital CA6 (Sankranthi v. El Camino Hospital CA6) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sankranthi v. El Camino Hospital CA6, (Cal. Ct. App. 2024).

Opinion

Filed 3/8/24 Sankranthi v. El Camino Hospital CA6 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SIXTH APPELLATE DISTRICT

RUTH SANKRANTHI, H049506 (Santa Clara County Plaintiff and Appellant, Super. Ct. No. 18CV334546)

v.

EL CAMINO HOSPITAL,

Defendant and Respondent.

Appellant Ruth Sankranthi1 was terminated from her position at El Camino Hospital (ECH). Sankranthi, who was pregnant at the time of her termination, brought an action against ECH alleging, inter alia, discrimination based on her gender and national origin, and wrongful termination after she became disabled due to pregnancy. The trial court granted summary judgment in favor of ECH. On appeal, Sankranthi argues that triable issues of material fact remained as to the discrimination, pregnancy disability, retaliation, and failure to prevent discrimination causes of action. She also challenges various evidentiary findings. Finding that summary judgment was properly granted, we will affirm the judgment.

Sankranthi’s last name was erroneously spelled as “Sankrathi” in the original 1

complaint, and the erroneous caption was used on documents filed in this court. On our own motion, we have corrected the caption used on appeal and will use the correct spelling of the appellant’s last name in this opinion. I. FACTS In October 2016, Jessica Hatala, then an interim manager in the Clinical Document Improvement (CDI) Department at ECH, interviewed Sankranthi for a CDI Specialist position. The position consisted primarily of daily clinical review of records to ensure accuracy of the records and medical coding, and to communicate with physicians to obtain missing or conflicting medical record documentation. This is a function of the hospital’s Clinical Quality Department. Hatala recommended that Sankranthi be hired with a salary of $130,000 per year. Sankranthi asked for, and Hatala approved, a higher salary of $147,000 per year. Sankranthi began working in December 2016. Hatala knew that Sankranthi identified as female and that her national origin was Indian. Hatala also hired three other CDI specialists, T.B. (who like Sankranthi was a female from India), Y.C. (an Asian female), and F.S.2 (a Black/Nigerian male). In the beginning, according to Sankranthi, she and Hatala had a “great” working relationship. However, Hatala noticed some problems. According to Hatala, Sankranthi “exhibited significant difficulties in performing her duties as a CDI Specialist as well as significant professionalism shortcomings.” In particular, Sankranthi did not compose “clinically valid queries to physicians,” her work resulted in “frequent coding mismatches,” and staff members complained to Hatala about Sankranthi’s “demeanor and manner of dress.” On April 10, 2017, Hatala noticed that Sankranthi and another CDI Specialist, C.E., a Mexican male, had a large number of cases marked “ ‘in progress,’ ” and as a result, informed them that they would not receive any new case assignments to provide them time to complete their cases. A week later, on April 18, 2017, Hatala noted that they had not completed the tasks, and sent both of them an e-mail requesting that they

2 F.S. is the father of the child Sankranthi was pregnant with at the time of her termination.

2 complete their assignment by week’s end. She also sent an e-mail to the entire CDI team, chastising them all for being late to a joint meeting with another department and for unprofessional conduct during the meeting. On April 20, 2017, Hatala sent an e-mail to human resources (HR) regarding Sankranthi and C.E., stating that their performance was not meeting expectations. With regard to Sankranthi, Hatala noted the following: “general unprofessional behavior, inappropriate dress and flirtatious behavior, calling her coworker and telling her to leave work early and not [to] do more work than [Sankranthi], general lack of participation in the Claro education, tardiness, generally needing more work and more redirection in her work, inability to recognize and act on query opportunities that are considered a core part of our CDI job, and what I can only describe as temper tantrums.” (“Claro” referred to Claro Health Care Consultants, which provided a two-week training program to the CDI’s in April 2017.) Hatala also noted that “[w]e already had a 1:1 about her attitude, but I have seen no improvement over the last two weeks.” Hatala asked for guidance on whether Sankranthi was eligible for a performance improvement plan (PIP), or if she could issue a written warning. In early July 2017, Sankranthi contacted HR, spoke to HR representative Faridah Hemani, and complained about Hatala. According to Hatala, Sankranthi alleged that Hatala was “ ‘targeting’ ” her by discussing her job performance shortcomings with her. According to Sankranthi’s deposition, her complaints about Hatala included: (1) Hatala told her she dressed like she was going to a club; (2) in front of other people, Hatala said she was surprised that Sankranthi owned pants; (3) Hatala waved her hand in front of Sankranthi’s face and said “Hello” at a group education meeting; (4) Hatala told Sankranthi and a coworker that they looked cute from behind and that she wanted to take their picture; and (5) Hatala repeatedly talked to Sankranthi in a demeaning manner. On July 11, 2017, Sankranthi met with HR representative Hemani, Catherine Carson (Senior Director of Quality and Hatala’s supervisor), and Hatala to discuss

3 Sankranthi’s concerns. Hatala acknowledged that she could be direct but emphasized to Sankranthi that she needed to dress professionally and reiterated that “coworkers had complained about [her] demeanor and dress . . . , including a comment that Ms. Sankranthi ‘dressed like she was going to the club,’ ” which Hatala had conveyed to Sankranthi. A few days later, on July 14, 2017, T.B. approached Hatala regarding concerns she had about Sankranthi. Later that day, Hatala summarized those concerns in an e-mail to HR and Carson. She reported that T.B. came to her because she felt “uncomfortable” around Sankranthi. T.B. reported that Sankranthi made multiple negative comments about Hatala, was not collaborating or talking with another colleague, and encouraged T.B. not to speak with or engage with that colleague. Hatala concluded by stating “it appears that [Sankranthi] is creating a toxic environment on the team and is having a negative effect on at least two members.” Hatala expressed her desire to “bring this out in the open and put an end to it once and for all.” Hatala summarized her ongoing concerns in a written memo to Sankranthi dated September 7, 2017, that documented her “Oral/Verbal Counseling” (hereafter “oral counseling”) sessions with Sankranthi that day and in April 2017. The memo noted that on April 3 and April 28, 2017, Hatala met with Sankranthi to discuss performance concerns, inappropriate work attire, and reports that Sankranthi encouraged another staff member to leave work when Sankranthi did and “not to send more queries than” Sankranthi did. The memo stated that Hatala had also received a report that Sankranthi told a coworker that they had been “ ‘doing too many reviews’ ” and engaged in “generally negative talk about the department.” And finally, the memo noted that “a staff member alerted [Hatala] and [her department’s] HR Business Representative, Hemani, that this department is a ‘toxic environment’ and the stress is impeding their work performance.”

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