Appleyard v. Governor Juan F. Luis Hosp. Med. Ctr. (Summary)

EMPLOYMENT AGREEMENTS

Appleyard v. Governor Juan F. Luis Hosp. Med. Ctr., S. Ct. Civ. No. 2014-0056 (D.V.I. Dec. 2, 2014)

The Supreme Court of the Virgin Islands affirmed a trial court’s ruling denying an orthopedic surgeon’s request for a preliminary injunction against a hospital. The surgeon requested the injunction in order to prevent the hospital from terminating her from its medical staff.

Issues arose after the hospital’s Medical Executive Committee received nine separate complaints about the behavior of the surgeon, five of which it deemed to be valid. Based on these complaints, the chair of the committee wrote to the surgeon to instruct her that she needed to undergo a psychiatric and psychological evaluation. After the surgeon failed to undergo the required evaluation, the hospital’s interim chief executive officer placed her on suspension.

The surgeon sued, alleging that she was suspended as retaliation for two complaints she had made, one about verbal harassment and one about a physician’s failure to admit a patient properly. However, a major obstacle for the surgeon was the expiration date on her employment agreement. Her hearing with the court was scheduled for August 1, 2014, but the employment agreement expired on July 31, 2014. Consequently, even if the court prevented the hospital from terminating her, it could not force the hospital to re-enter another employment agreement.

To overcome this problem, the surgeon argued that the court should instead follow the date that was set on her relocation agreement with the hospital, which lasted until July 31, 2015. She claimed that the documents should be read together since they were executed simultaneously. However, the lower court concluded that there was no evidence to show that the relocation agreement was meant to extend her employment agreement for another year. It denied her request for a preliminary injunction. On appeal, the Supreme Court of the Virgin Islands upheld the decision. It noted that there were errors in the way that the lower court handled certain public policy issues implicated in the case, but determined that there was no reason to disturb the overall decision to deny the preliminary injunction.