Madsen v. Idaho Emergency Physicians, P.A. – Summary

TITLE VII

Madsen v. Idaho Emergency Physicians, P.A. , No. CV-09-243-S-EJL (D. Idaho July 22, 2010)

The United States District Court for the District of Idaho granted a physician’s motion to reconsider an order of summary judgment against her in an employment discrimination case she filed against a physician group. The court found that the physician’s claims were not time-barred because a 300-day statute of limitations applied to the physician’s claims.

The physician had initially filed her complaint with an Idaho human rights agency that had a work share agreement with the Equal Employment Opportunity Commission ("EEOC"), which allowed the agency to constructively receive EEOC charges as the EEOC’s agent. The work share agreement allowed a party to file a charge with a state agency within 240 days of the alleged unlawful employment practice and trigger the 300-day statute of limitations.

The court also agreed to reconsider whether the physician alleged an act contributing to her hostile work environment claim against the group within the 300-day period and whether the continuing harm doctrine could be applied to her hostile work environment claim.