Rouhani v. Bronson Battle Creek Hosp. (Summary)

SEXUAL HARASSMENT

Rouhani v. Bronson Battle Creek Hosp.
No. 315121 (Mich. Ct. App. July 15, 2014)

The Michigan Court of Appeals upheld a lower court’s ruling dismissing a psychiatrist’s sexual harassment claim against a hospital, holding that the psychiatrist failed to establish that there was any connection between the alleged harassment and a tangible employment action. After the psychiatrist received three letters concerning her quality of care, the Vice President of Medical Affairs at the hospital met with her to discuss how to improve her quality of care going forward. The psychiatrist alleged that, during this meeting, the VPMA made sexual comments to her and fondled her hand. The psychiatrist alerted the hospital and it conducted an investigation of the incident but was unable to determine whether any inappropriate conduct occurred. After the investigation, the psychiatrist alleged that her referrals decreased dramatically. The psychiatrist brought quid pro quo sexual harassment and retaliation claims against the hospital.

The court held that the psychiatrist failed to establish that there was any connection between the decrease in referrals and the alleged sexual conduct or her complaint. The court stated that an employee must show more than just a temporal connection between the alleged harassment and the adverse action; there needs to be evidence that one caused the other. Here, the psychiatrist only made conclusionary statements.