Alexander v. Trilogy Health Services, LLC, 1:11-cv-00295

Background

Tasha Alexander, an LPN at Trilogy’s Triple Creek in Cincinnati, began working May 6, 2009 and received training and a handbook outlining attendance and FMLA procedures.
Alexander became pregnant in May 2010; shortly after, she faced multiple disciplinary actions in July–August 2010 culminating in a final written warning and suspension.
In August 2010, Alexander informed management she could not work due to pregnancy-related high blood pressure; the company later suspended her pending investigation.
Trilogy’s policy changes regarding FMLA were not reflected in the employee handbook; Matrix, the third‑party FMLA administrator, was not properly integrated into employee notices.
Plaintiff contends she was terminated for pregnancy and subsequently filed an EEOC charge; Trilogy terminated her effective October 26, 2010 for alleged job abandonment.
Plaintiff asserts ADA disability discrimination (pregnancy-related hypertension) and FMLA interference; the court addresses these claims on cross motions for summary judgment.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there prima facie pregnancy discrimination?	Alexander: pregnancy treated less favorably than similar nonpregnant workers.	Trilogy: discipline for performance/attendance, not pregnancy.	Prima facie case found; summary judgment denied on pregnancy claims.
Did Trilogy offer a legitimate nondiscriminatory reason for termination/suspension?	Disciplinary actions tied to pregnancy; pretext possible.	Suspension/termination based on attendance and care violations.	Defendant proffered nondiscriminatory reasons but issues of pretext remained; disputes insufficient for summary judgment.
Did the management’s alleged negative comments support discriminatory motive?	Management expressed concerns about staffing due to pregnancy, signaling bias.	Staffing concerns unrelated to pregnancy; comments not probative of discrimination.	Evidence of negative comments supports discriminatory motive; factual disputes remain.
Was Plaintiff properly accommodated under the ADA?	She requested a brief medical leave as accommodation for preeclampsia.	No explicit accommodation request; no obligation to provide leave.	Plaintiff's hospitalization/leave evidence supports a reasonable accommodation claim; disability claim can proceed.
Did Trilogy interfere with Plaintiff’s FMLA rights?	Failure to provide written notice of Matrix process and failure to reinstate after leave.	Procedural gaps argued; Plaintiff did not complete FMLA paperwork.	FMLA interference proven; plaintiff entitled to judgment on that claim.

Key Cases Cited

Tysinger v. Police Dep’t of City of Zanesville, 463 F.3d 569 (6th Cir. 2006) (pregnancy discrimination requires equal treatment to similarly situated nonpregnant employees)
Reeves v. Swift Transp. Co., 446 F.3d 637 (6th Cir. 2006) (burden-shifting framework after prima facie case; pretext analysis)
Kleiber v. Honda of Am. Mfg., Inc., 485 F.3d 862 (6th Cir. 2007) (ADA direct evidence framework for reasonable accommodation claims)
Cehrs v. Northeast Ohio Alzheimer's Research Ctr., 155 F.3d 775 (6th Cir. 1998) (individualized inquiry for medical leave accommodations under ADA)
Cavin v. Honda of Am. Mfg., Inc., 346 F.3d 713 (6th Cir. 2003) (ADA case; employer burden to justify accommodations or discrimination claim)
Kocak v. Community Health Partners of Ohio, Inc., 400 F.3d 466 (6th Cir. 2005) (Title VII/Ohio 4112 claims analyzed consistently with federal standards)