Carson v. Univ. of Chi. Med. Ctr. (Summary)

DISCRIMINATION

Carson v. Univ. of Chi. Med. Ctr., No. 12 C 5753 (N.D. Ill. Sept. 29, 2014)

The United States District Court for the Northern District of Illinois dismissed a former employee’s race discrimination claim, holding that the employee failed to show that similarly situated employees were treated more favorably or that any alleged racial animus was a proximate cause of her termination. Plaintiff, an African-American, was employed as the director of the infusion therapy unit at the hospital. The employee received multiple deficient performance reviews and was placed on a performance improvement plan to improve her collaboration, teamwork, and communication.

Thereafter, the hospital performed a “climate assessment” on the employee’s unit in response to complaints from 11 of her subordinates. After the climate assessment, the hospital’s director of human relations terminated the employee because the employee did not follow the requirements of her performance improvement plan and she created a work environment that was intimidating, humiliating, belittling and unprofessional.

The employee sued claiming race discrimination. The employee alleged that other employees were treated more favorably after a “climate assessment,” and co-workers allegedly made racist comments to her.

The court dismissed the employee’s discrimination claim, holding that the employee failed to show that similarly situated employees were treated more favorably, and any alleged racial animus was a proximate cause of her termination. The employee did not provide any evidence that other employees who received a climate assessment were similarly situated to her, or received better treatment. Additionally, the court stated that there was no link between any alleged racial comments and the person who made the termination decision. Lastly, the court stressed that the hospital provided a legitimate reason for terminating the employee – she did not perform her job satisfactorily.