Claire Trott v. H.D. Goodall Hospital
2013 ME 33
| Me. | 2013Background
- Trott worked as a nurse for about nineteen years with largely positive evaluations prior to 2007.
- A patient died during Trott’s shift in December 2007 and Trott discussed possible causes with the patient’s daughter, prompting a wrongful death suit against the Hospital.
- In 2009 Trott was deposed in the wrongful death case; the Hospital later discharged her on grounds related to a misentry in a patient record.
- Trott testified in the deposition about observing the patient as asleep and later contradicted by the medical record entry showing the patient as alert, leading Trott to offer an explanation she later disputed.
- The Hospital terminated Trott on March 26, 2009, reporting the discharge to the Maine State Board of Nursing and citing additional concerns about documentation and medication administration.
- Trott sued under the WPA, alleging discharge for participating in the deposition; the trial court granted summary judgment for the Hospital, which Trott appeals.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether deposition participation is a 'court action' under WPA § 833(1)(C). | Trott argues deposition participation is protected. | Hospital contends only deposition content is protected, not participation. | Deposition is a court action protected by § 833(1)(C). |
| Whether there is a causal link between Trott's deposition participation and her discharge. | Trott produced evidence of a temporal nexus suggesting retaliation. | Hospital asserts discharge based on falsification, a legitimate non-discriminatory reason. | A genuine issue of material fact exists on causation/pretext; summary judgment should be vacated. |
| Whether the McDonnell Douglas burden-shifting framework is required at summary judgment for WPA discrimination claims. | Trott need only raise an issue of fact on causation; the framework is not required. | Hospital relies on McDonnell Douglas to structure the analysis. | Court proceeds with a prima facie/legitimate-reason/pretext analysis; summary judgment suitable only if no genuine issue of material fact. |
| Whether Trott met her initial burden by showing a close causal nexus between protected activity and discharge. | Discharge occurred 41 days after deposition and 1 day after transcript, showing nexus. | Discharge was for falsification of records, independent of deposition. | Trott showed a temporal nexus sufficient to shift to Hospital to justify its reason. |
| Whether the Hospital’s stated reason for discharge was pretext to conceal retaliation for the WPA activity. | Record evidence suggests contradictions and possible intentional framing. | Falsification of records supports discharge regardless of protected activity. | Record contains questions of credibility and possible pretext; material fact issues remain. |
Key Cases Cited
- Costain v. Sunbury Primary Care, P.A., 954 A.2d 1051 (Me. 2008) (causation standard for WPA retaliation claims)
- Doyle v. Dep’t of Human Servs., 824 A.2d 48 (Me. 2003) (McDonnell Douglas framework context in discrimination claims)
- Fuhrmann v. Staples the Office Superstore E., Inc., 58 A.3d 1083 (Me. 2012) (three-step burden-shifting framework in discrimination context)
- Cookson v. Brewer Sch. Dep’t, 974 A.2d 276 (Me. 2009) (credibility issues rarely resolved at summary judgment)
- Arrow Fastener Co. v. Wrabacon, Inc., 917 A.2d 123 (Me. 2007) (summary judgment standard and pretext evaluation)
- Daniels v. Narraguagus Bay Health Care Facility, 45 A.3d 722 (Me. 2012) (summary judgment and consideration of circumstantial evidence in discrimination cases)
- Levesque v. Androscoggin Cnty., 56 A.3d 1227 (Me. 2012) (de novo standard for summary judgment review)