Dianna Jackson v. Trinity Health-Michigan
656 F. App'x 208
| 6th Cir. | 2016Background
- Dianna Jackson, a 58-year-old African‑American, served as director of radiology at St. Joseph Mercy Oakland (Trinity Health) from Nov. 2007 until her termination effective Jan. 7, 2011.
- Over ~2008–2010 multiple supervisors and staff complained about Jackson’s management: described as confrontational, “dictatorial,” and failing to resolve interpersonal conflicts; documented performance concerns (evaluations, physician complaints, incidents involving surplus computers and payroll queries).
- Hospital supervisors coached Jackson repeatedly, held mediation meetings with her and two subordinate managers (Erika Page and Colleen Ealy), and directed her to submit a remediation plan; she did not produce an adequate plan and took medical leave instead.
- Trinity terminated Jackson citing breakdown of the management team, poor leadership, unresolved conflicts, and loss of confidence in department operations; she was replaced by a white director (Donna Moir).
- Jackson sued claiming race discrimination (Title VII and Michigan’s Elliott‑Larsen), age discrimination (ADEA), and retaliation (state law). The district court granted summary judgment for Trinity; the Sixth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Race discrimination (Title VII & Elliott‑Larsen) | Jackson contends she was fired because of race; she points to replacement by a white successor and alleged disparate treatment by supervisors/subordinates. | Trinity asserts termination was for legitimate, nondiscriminatory reasons: repeated complaints about Jackson’s leadership, poor interpersonal judgment, and unresolved operational problems. | Court: Jackson established a prima facie case (replaced by person outside class) but failed to show Trinity’s stated reasons were pretextual; summary judgment for Trinity affirmed. |
| Age discrimination (ADEA) | Jackson points to a comment characterizing her style as “old school” as direct evidence of age bias. | Trinity argues the remark is isolated, ambiguous, and not made by a decisionmaker; no other evidence of age bias. | Court: remark too abstract/ambiguous to constitute direct evidence; ADEA claim fails. |
| Retaliation (Elliott‑Larsen) | Jackson alleges she was retaliated against for asserting race discrimination. | Trinity notes Jackson did not allege protected activity and failed to oppose summary judgment on this claim. | Court: Jackson waived the retaliation claim for failure to press it; claim dismissed. |
| Summary judgment / prima facie burden | Jackson argues district court erred in requiring similarly situated comparator rather than allowing replacement evidence. | Trinity contends plaintiff failed to show pretext and there is no genuine dispute of material fact. | Court: district court misframed prima facie inquiry (replacement sufficed), but even considering McDonnell Douglas burden‑shifting, Jackson failed to raise a genuine issue of pretext; summary judgment affirmed. |
Key Cases Cited
- Dodd v. Donahoe, 715 F.3d 151 (6th Cir.) (standard of review for summary judgment)
- Ciminillo v. Streicher, 434 F.3d 461 (6th Cir. ) (genuine‑dispute standard at summary judgment)
- Wexler v. White’s Fine Furniture, Inc., 317 F.3d 564 (6th Cir.) (pretext framework for employment discrimination)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S.) (prima facie burden‑shifting framework)
- Texas Dep’t of Cmty. Affairs v. Burdine, 450 U.S. 248 (U.S.) (defendant’s burden to articulate nondiscriminatory reason)
- Laster v. City of Kalamazoo, 746 F.3d 714 (6th Cir.) (elements of prima facie case under Title VII and Elliott‑Larsen)
- Wrenn v. Gould, 808 F.2d 493 (6th Cir.) (employer discretion in management decisions)
- Town v. Michigan Bell Tel. Co., 568 N.W.2d 64 (Mich.) (Elliott‑Larsen: plaintiff must show employer’s reason was pretext and discrimination was motivating factor)
- Lytle v. Malady, 579 N.W.2d 906 (Mich.) (state adaptation of McDonnell Douglas framework)