Hill v. St. James Hosp. & Health Ctrs. (Summary)

TITLE VII – RACE DISCRIMINATION

Hill v. St. James Hosp. & Health Ctrs., No. 10 C 5780 (N.D. Ill. Feb. 15, 2013)

The United States District Court for the Northern District of Illinois granted a hospital’s motion for summary judgment on a Title VII discrimination claim and state law retaliation claim brought by a female, African-American nurse.   The nurse’s position in the hospital’s cath lab was eliminated because of an increase in the cost of performing procedures in the lab.  Another contributing factor to the elimination of the nurse’s position was a significant decline in the number of cases conducted after a group of doctors that performed all of the procedures in the lab did not renew its contract with the hospital.  The nurse was informed of other openings at the hospital, but the nurse was not interested.  She was then offered a severance package.  However, the nurse declined the severance package because she wanted to collect unemployment benefits.

The nurse sued the hospital and claimed that the elimination of her position constituted race discrimination in violation of Title VII.  The court rejected the nurse’s claims, finding that she failed to establish that her responsibilities were taken on by other individuals in the workforce of a different race or that other individuals of a different race were treated better.  Even if the nurse had shown that a Caucasian nurse was similarly situated to her or that she had taken on the nurse’s responsibilities, the hospital’s cath lab was under financial pressure due to increased costs and decreased procedures. Therefore, the hospital had a legitimate reason to eliminate the nurse’s position.  The court also rejected the nurse’s retaliatory discharge claim under state law, concluding that such a claim was not cognizable because a remedy was available under the Illinois Human Rights Act.