Janice Wright v. St. Vincent Health System
2013 U.S. App. LEXIS 19242
| 8th Cir. | 2013Background
- Wright, an African-American surgical technologist, began night shift work in the hospital’s operating room in 2008 sharing duties with Bell until Bell’s injury reduced Wright’s support.
- After Bell’s absence, Wright handled night duties largely alone, leading to performance issues and multiple disciplinary actions in Sept. 2008 and Jan. 2009.
- Wright received disciplinary forms for September 2008, including a counseling form and a failure to complete checklists and report events, with an implied threat of termination for future issues.
- In July 2009, Wright was terminated by Sacker following a phone call during which Wright allegedly showed anger; the hospital claimed insubordination rather than race-based motive.
- Wright complained of racial discrimination on July 10, 2009 and later filed an EEOC charge on September 16, 2009; she sued in April 2010, alleging Title VII and § 1981 discrimination and retaliation.
- The district court, after a two-day bench trial, entered judgment favoring the hospital, and Wright appealed challenging the factual and legal determinations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Wright proved retaliation for protected activity. | Wright argues timing shows but-for retaliation for the discrimination complaint. | Hospital contends timing is not determinative and other non-retaliatory reasons governed termination. | No clear error; district court’s non-retaliatory rationale upheld. |
| Whether Wright proved disparate treatment based on race in termination. | Statistics and supervisor treatment show race-based discrimination. | District court credited non-discriminatory explanations and found no causative discrimination. | Discriminatory motive not shown; district court’s factual findings affirmed. |
| Whether Wright proved disparate terms and conditions of employment due to race. | Wright was burdened with duties beyond comparators and denied transfers available to others. | Differences in duties reflect hospital productivity decisions, not race. | No reversible error; evidence supported non-discriminatory explanations. |
| Whether the district court’s credibility determinations were clearly erroneous. | Wright challenges Sacker and Cockrell credibility. | Court correctly credited management witnesses and rejected Wright’s version. | Credibility findings upheld; not clearly erroneous. |
| What standard governs causation in retaliation claims under Title VII and § 1981. | Contends standard requires direct evidence or strong inference of retaliation. | The court applied a causation standard requiring but-for or determining-factor proof. | Court applying appropriate standard; but-for causation required. |
Key Cases Cited
- Kim v. Nash Finch Co., 123 F.3d 1046 (8th Cir. 1997) (identical standards for Title VII and §1981 retaliation and discrimination)
- Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53 (U.S. 2006) (rule that retaliation claims require material adverse action)
- Tex. Dep’t of Cmty. Affairs v. Burdine, 450 U.S. 248 (U.S. 1981) (burden-shifting framework for discrimination proof)
- Aikens, U.S. Postal Serv. Bd. of Governors v., 460 U.S. 711 (U.S. 1983) (pretext and credibility in discrimination cases)
- Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (U.S. 2000) (evidence standards for proving intentional discrimination)
- Anderson v. City of Bessemer City, 470 U.S. 564 (U.S. 1985) (reliability of credibility determinations in mixed evidence)
- Kiel v. Select Artificials, Inc., 169 F.3d 1131 (8th Cir. 1999) (temporal proximity alone insufficient for retaliation)
- Williams v. Ford Motor Co., 14 F.3d 1305 (8th Cir. 1994) (requirements for similarly situated comparisons in discrimination proof)
- Carrington v. City of Des Moines, 481 F.3d 1046 (8th Cir. 2007) (determinative vs motivating factor in retaliation analysis)