Stevens v. Saint Elizabeth Med. Ctr., Inc. (Summary)

SEX DISCRIMINATION

Stevens v. Saint Elizabeth Med. Ctr., Inc., No. 12-5243 (6th Cir. Aug. 29, 2013)

The United States Court of Appeals for the Sixth Circuit affirmed the grant of summary judgment in favor of a medical center for claims of, among others, sexual harassment, gender discrimination and retaliatory discharge under Title VII and the Kentucky Civil Rights Act, brought by a nurse, who was terminated because of her romantic relationship with the CEO of the Physician Group.  The court found that, although inappropriate actions occurred in the workplace, the CEO’s relationship with the nurse did not create a hostile work environment such that it unreasonably interfered with her work performance.

The nurse’s retaliatory discharge claims also failed because not only was the CEO also terminated, but he had no control over her discharge.  The court found that the medical center offered legitimate non-discriminatory reasons for her termination, including her in-office sex and the ongoing office disruption resulting from the relationship.