Hudson v. Cleveland Clinic Foundation, 1:23-cv-02182

Plaintiff Christy Hudson, a Black woman, was employed by Cleveland Clinic Foundation (CCF) as a Blood Bank laboratory supervisor from 2004 until her termination in December 2022.
Hudson’s performance came under scrutiny following several employee complaints, negative survey feedback, and regulatory inspections identifying deficiencies related to her job responsibilities.
During her tenure, Hudson took approved FMLA leaves, and was disciplined and eventually terminated after repeated performance issues, including failures highlighted by AABB and FDA inspections.
After her termination, Hudson, without appealing the decision internally, filed suit alleging race discrimination under Title VII and the Ohio Civil Rights Act, and retaliation under the FMLA.
CCF moved for summary judgment, arguing Hudson could not meet her legal burdens on either claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Prima facie case of racial discrimination	Hudson was qualified, suffered adverse action, and replaced by a White employee; comparables (like Brenner) treated more favorably	She was not similarly situated to Brenner; no evidence of replacement suggesting discrimination, termination due to performance	Hudson did not show similarly situated comparator or replacement sufficient; summary judgment for CCF
Legitimate non-discriminatory reason	Deficiencies in performance did not justify termination; discipline was pretextual	Numerous documented performance issues, including those verified by regulatory bodies and HR records	CCF showed a legitimate, non-discriminatory reason; no pretext shown
FMLA retaliation	Discipline and termination temporally linked to FMLA leave; mention of FMLA leave in criticisms	No direct evidence of retaliation; substantial time gap between leave and adverse action	No causal link between FMLA leave and adverse action; summary judgment for CCF
Use of comparators	Brenner and others were similarly situated and treated better	Brenner was not similarly situated (shorter tenure, fewer deficiencies, different responsibilities)	No proper comparator; differences in circumstance undermined claim

Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summarizes summary judgment standard)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (lays out burden-shifting framework for discrimination claims)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (standards for nonmovant’s burden at summary judgment)
Wexler v. White’s Fine Furniture, Inc., 317 F.3d 564 (objective qualifications vs. performance for prima facie case)
Mitchell v. Toledo Hospital, 964 F.2d 577 (requirements for comparator in discrimination cases)