Daniels v. Narraguagus Bay Health Care Facility
45 A.3d 722
| Me. | 2012Background
- Narraguagus Bay Health Care Facility operates a Milbridge nursing home; North Country Associates provides administrative support and has at least once supplied an administrator.
- Daniels began as a maintenance assistant in 2007 with duties including regulatory compliance tasks; he suffered a work-related right shoulder injury in Oct 2007 and received light-duty restrictions.
- He underwent shoulder surgery in Jan 2008 and went on a medical leave; in Mar 2008 he sought more leave and claimed a lack of accommodation for his disability.
- Daniels was rehired in Dec 2008 (initially as maintenance, then promoted to maintenance director in Feb 2009); he had a July 2009 second shoulder injury with a three-month modified-duty period.
- Nov 2009, after restrictions ended, Daniels received a performance improvement plan; Dec 30, 2009 he reported elbow pain; Jan 29, 2010 he was terminated—tied to a licensing inspection issue—and the Commission had issued a right-to-sue letter on Nov 30, 2009.
- Daniels filed a Maine Human Rights Act complaint in Aug 2008 alleging disability discrimination; both Narraguagus and North Country were aware of the right-to-sue letter and the later complaint; Daniels sued in state court seeking discrimination and retaliation, and the defendants moved for summary judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Discrimination based on disability against NarraguagusBay | Daniels shows disability, qualification, and adverse action | Record lacks undisputed causal link between disability and discharge | Not entitled to summary judgment; triable issues exist |
| Retaliation by Narraguagus for protected activity | Timing and email evidence show causation | Discretionary factors could explain termination | Summary judgment vacated; triable issue |
| North Country's liability for discrimination | Integrated-enterprise theory or aiding Narraguagus applies | No clear basis without more facts | Remanded for fact-finding on North Country's involvement |
| North Country's liability for retaliation | Could have participated in discharge due to Commission complaint | No direct evidence of retaliation | Summary judgment vacated; remand for further proceedings |
Key Cases Cited
- Whitney v. Wal-Mart Stores, Inc., 2006 ME 37 (Me. 2006) (prima facie elements of discrimination under MHRA)
- Cookson v. Brewer Sch. Dep't, 2009 ME 57 (Me. 2009) (summary judgment burdens in discrimination claims)
- Doyle v. Dep't of Human Servs., 2003 ME 61 (Me. 2003) (three-step burden-shifting analysis for discrimination claims (McDonnell Douglas))
- Auburn v. City of Auburn, 408 A.2d 1253 (Me. 1979) (measures for prima facie discrimination showing; integrated enterprise context)
- St. Mary's Honor Ctr. v. Hicks, 509 U.S. 502 (U.S. 1993) (McDonnell Douglas framework; burden-shifting purpose at summary judgment and trial)
- Barzingus v. Wilheim, 306 F.3d 17 (10th Cir. 2010) (discussion of summary judgment standards in discrimination cases)