Woody v. Covenant Health (Summary)

AGE DISCRIMINATION

Woody v. Covenant Health, No. 3:11-cv-62 (E.D. Tenn. May 8, 2013)

In this employment discrimination case, the U.S. District Court for the Eastern District of Tennessee granted in part and denied in part a medical center’s motion for summary judgment.  The motion concerned a nurse who had brought suit against the medical center, claiming that she was discriminated against based on her age. The nurse was one of four shift leaders who were told that the position of shift leader was changing, and that they would all have to reapply for the shift leader positions.  During that process, it was rumored that the nurse’s position would be given to a younger nurse, highlighted by the nursing supervisor’s flyers indicating that she was looking for “young rising stars.” The nurse lost her shift leader position to a younger individual, but maintained a job as a registered nurse in the medical center.

The district court held that the nurse had brought enough evidence of age discrimination to survive a motion of summary judgment.  The nurse’s supervisor advertised the position as one for “young rising stars,” and told the interview team that she was looking for a younger nurse to fill the position. Even though the supervisor was not a decision-maker in the hiring process, her influence on the interview team was material.  The court rejected the medical center’s argument that the nurse simply changed roles and did not go through a job change.  The court stated that the loss of title, prestige and salary that came with losing the shift leader position were all indications of a potentially discriminatory job change.  The court determined that summary judgment was inappropriate because it was possible that a reasonable jury could find that the nurse was discriminated against during the reapplication process.

The district court granted the medical center’s motion in regards to punitive damages.  The court stated that punitive damages are not normally recoverable in age discrimination cases.