Thomas v. Baptist Health Sciences University

CourtDistrict Court, W.D. Tennessee
DecidedApril 11, 2025
Docket2:23-cv-02595
StatusUnknown

This text of Thomas v. Baptist Health Sciences University (Thomas v. Baptist Health Sciences University) is published on Counsel Stack Legal Research, covering District Court, W.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Thomas v. Baptist Health Sciences University, (W.D. Tenn. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TENNESSEE WESTERN DIVISION CHARLETTA THOMAS, ) ) Plaintiff, ) v. ) No. 2:23-cv-02595-SHL-tmp ) BAPTIST HEALTH SCIENCES ) UNIVERSITY, ) Defendant. ) ORDER GRANTING DEFENDANT’S MOTION FOR SUMMARY JUDGMENT, DENYING AS MOOT DEFENDANT’S MOTION TO STRIKE, AND DENYING AS MOOT THE JOINT MOTION TO CONTINUE TRIAL SETTING Defendant Baptist Health Sciences University (“BHSU”) seeks summary judgment on Plaintiff Charletta Thomas’s claims under the Age Discrimination in Employment Act and the Tennessee Human Rights Act. (ECF No. 21 at PageID 65–66.) Thomas responded in opposition1 (ECF No. 23), and BHSU replied (ECF No. 27). Even if Thomas could assert a prima facie case of discrimination under the ADEA and retaliation under the THRA, she has no evidence that BHSU’s decisions not to hire her were pretextual. Thus, BHSU’s motion for summary judgment is GRANTED. BACKGROUND2 Baptist Memorial Health Care Corporation (“Baptist”) is the functional parent 1 Although Thomas timely filed her substantive response to the motion, she filed her response to BHSU’s statement of material facts a day late. (ECF No. 26 at PageID 430.) BHSU attempted to consult with Thomas’s counsel about the delay, but counsel neglected to timely respond and BHSU filed a motion to strike the filing. (ECF No. 29 at PageID 502–03.) After BHSU filed its motion, Thomas’s counsel explained that he encountered technical difficulties when trying to file the document. (Id. at PageID 503.) Given that explanation, BHSU withdrew its motion to strike. (Id. at PageID 502–03.) Thus, that motion is DENIED AS MOOT. 2 Unless otherwise noted, neither party disputed these facts in their statements of material facts. corporation in a family of related organizations.3 (ECF No. 24 at PageID 392.) The Baptist family includes subsidiaries that operate hospital facilities and other business entities. (Id.) One such subsidiary is BSHU (id.), a health sciences college (id. at PageID 393). BHSU educates health care professionals across sixteen different specialties and regularly confers associates,

bachelor’s, and doctoral degrees to students. (Id.) It is comprised of three divisions: general education and health studies, allied health, and nursing. (Id.) It also has a College of Osteopathic Medicine. (Id.) For the most part, Baptist and BHSU operate independently at separate locations. (Id. at PageID 392.) BHSU makes its own hiring, firing, and disciplinary decisions through its own employees and local, on-site Human Resources professionals. (Id.) But Baptist does provide BHSU with support services to assist with human resources, recruiting, and application technology. (Id.) And prospective employees view open jobs across the entire family of Baptist organizations. (Id.) Individuals who wish to apply for a Baptist job must create an online account that houses

their open applications and communications with talent acquisition professionals. (Id. at PageID 392, 394.4) Recruiting professionals conduct a preliminary review of completed applications to ensure that each applicant has the requisite education or licensure. (Id. at PageID 394.) Then, the hiring manager determines who to interview based on the total pool of qualified applicants. (Id.) To maintain a neutral hiring process, hiring managers never receive or view an applicant’s

3 Because Thomas references her applications for separate Baptist positions outside of BHSU in support of her claims against BHSU, it is necessary to explain how Baptist is involved. 4 The pages of Thomas’s response to BHSU’s statement of material facts do not appear in order. The first page of the filing is the tail end of a blank page without any text; the page numbered as “2” appears before the page numbered as “1”; the page numbered “6” appears after the page numbered “4”; and so on. (See generally ECF No. 24.) The Court will do its best to extrapolate the order in which the pages are intended to appear. personally identifiable information. (Id.) And they do not further investigate each candidate beyond the initial qualification check. (Id.) According to Baptist, typically, it is not until after a candidate is selected for hire that a background check and prior internal employment records are ordered and reviewed to verify that a candidate is eligible for rehire.5 (Id.) The decision as to

whether to process records checks before or after hiring decisions are made depends on recruitment caseload and recruiter preferences. (Id. at PageID 394–95.) But checks are always done before the start of employment. (Id.) In the fall of 2021, BHSU opened applications for an Academic Success Coach position in the Blue Healer Student Success Center. (Id. at PageID 395.) BHSU created the Success Center after receiving a significant grant from the Department of Education under its Predominantly Black Institutions Competitive Grant Program. (Id.) The Success Center provides students with access to resources like tutoring, mentoring, and academic success planning to help them achieve their academic and career goals. (Id.) Thomas applied for the ASC position in November 2021. (Id.) She was forty-nine years

old when she submitted her application. (Id.) The ASC Supervisor, Mary Margaret Freeman, was the designated hiring manager for the ASC role. (Id. at PageID 395, 397.) Freeman selected

5 Thomas disputes this fact because she applied for positions at Baptist but was only informed that she was ineligible for rehire after she filed a charge of discrimination with the EEOC. (ECF No. 24 at PageID 394.) However, Thomas’s support for her dispute only confirms BHSU’s position—Baptist typically does not check to see if a candidate is eligible for rehire until after a candidate is selected for hire. Thus, Baptist would not have informed Thomas that she was ineligible for rehire during the initial stage of reviewing applications. Thomas also does not cite to any fact in the record that disputes BHSU’s description of the process. She only cites to her own allegations in the complaint and BHSU’s answer, which do not contradict the fact in question. She admitted in her deposition that she does not “know anything about the process for determining whether somebody’s eligible for rehire.” (ECF No. 21-5 at PageID 225.) And she did not dispute that “[n]o further investigation is done” beyond an initial check to ensure each applicant has the requisite education and licensure. (ECF No. 24 at PageID 394.) Thomas for an interview, and both she and the Dean of Student Success, Dr. Kim Cunningham, conducted the first interview. (Id.) Afterwards, Freeman invited Thomas and five other applicants back for a second interview. (Id. at PageID 397.) The second-round applicants interviewed with a panel of BHSU employees including

Freeman, Dr. Cunningham, Mellody Selph, Molly Antoine, and Lynn Anderson. (Id.) Freeman required the applicants to prepare a presentation about one of the following topics: goal setting and motivation, study skill strategies, time management, note taking skills, test-taking strategies, and reading comprehension skills. (Id.) After the presentation, the panel asked questions about the topic as well as the applicant’s resume and background information. (Id.) Each member of the panel had a list of twelve suggested questions, but anyone could ask additional clarifying questions. (Id.) During Thomas’s second interview, Anderson expressed confusion about the timeline of her resume and asked her about her education and experience. (Id.) Thomas admits that “her resume contained errors and misleading entries.” (Id. at PageID 396.) Her resume indicates that

she received two separate associate degrees, but she only earned one. (Id.) It states that she was an academic advisor and managed a “team” of employees, but she was only a volunteer advisor and did not manage or supervise anyone.

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Bluebook (online)
Thomas v. Baptist Health Sciences University, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thomas-v-baptist-health-sciences-university-tnwd-2025.