Willis v. UPMC Children’s Hosp. of Pittsburgh — Dec. 2015 (Summary)

AGE DISCRIMINATION

Willis v. UPMC Children’s Hosp. of Pittsburgh
No. 15-1526 (3d Cir. Dec. 22, 2015)

After a neonatal nurse practitioner was terminated by the hospital that employed her, the nurse alleged that she was discriminated against based on her age. She brought an action under the Age Discrimination in Employment Act and the Pennsylvania Human Relations Act.

The court found that the plaintiff met a number of the necessary elements of a prima facie case of age discrimination: she was over 40 years old, had suffered an adverse employment decision, and was qualified for the position. However, the fourth required element was not met: the position that the nurse vacated was not filled until a year after her demotion. Additionally, the court found that the nurse failed to establish that the disciplinary events her employer cited as cause for her termination were mere pretext. The court held in favor of the employer on both claims.