Zuurbier v. Medstar Health Inc., No. 05-CV-13 (D.C.
Apr. 6, 2006)
The District of Columbia Court of Appeals found that an error in a physician’s discrimination complaint, which named a health system as the defendant (rather than its subsidiary that actually operated the hospital where the physician was employed), was not so prejudicial as to prevent the resolution of the dispute on its merits. The physician claimed she was the subject of sexual discrimination in the form of disparate pay and that she was forced to resign due to a hostile environment.
The trial judge granted the health system’s motion for summary judgment on the constructive discharge claim, finding that the physician’s claim had not been timely filed due to an error in the original complaint. On appeal, the district court reversed the trial court’s grant of summary judgment in favor of the health system with respect to the physician’s constructive discharge claim. However, the district court held that the physician could only claim the paychecks issued to her less than one year before she brought suit and was time-barred from recovering damages for all earlier paychecks.