Simpson v. St. James Hosp. – July 2015 (Summary)

EMPLOYMENT DISCRIMINATION – NURSING

Simpson v. St. James Hosp., No. 13 CV 5857 (N.D. Ill. July 8, 2015)

The United States District Court for the Northern District of Illinois granted a hospital summary judgment in a nurse’s suit that alleged that she was fired because she was female, African-American, over 40, or pregnant. The hospital asserted that it fired the nurse because she had a two-year pattern of rude and otherwise inappropriate behavior. Between the months of October 2010 and September 2011, the nurse had seven incidents cited and recorded on forms called “Employee Corrective Action Reports.” The conduct written in these reports ranged from disobeying doctors’ orders to removing a patient’s morphine pump as an act of retaliation for complaining about the care provided.

The court found that there was no basis to the nurse’s claims that the hospital applied its rules against her more strictly due to her gender or pregnancy. The court applied further analysis to determine if the hospital’s reasons for the nurse’s termination were pretextual for racial and age discrimination. Because there was undisputed evidence of the nurse violating hospital rules, the court found that the hospital’s proffered explanations were not pretextual, and these violations served as a nondiscriminatory basis of the nurse’s termination.