Johana Cabantac Arucan v. Cambridge E. Healthcare Center, 18-1447

Background

Arucan, a physical therapy assistant at Cambridge East Healthcare (hired 2012), mistakenly treated the wrong patient on Jan. 5, 2016; she admitted the error and signed a statement acknowledging it could be terminable.
Cambridge terminated Arucan on Jan. 8, 2016; a dispute at the facility led to police being summoned and Officers Heinrich and Zamojski arresting her for trespass; she pleaded no contest to trespassing and entered a plea agreement that included a broad release of the City and its officers.
Arucan (pro se, later with counsel) sued Cambridge, supervisors Vantiem and Reusser, and the two officers asserting Title VII discrimination (race, color, sex, national origin), hostile work environment, § 1983 claims for unlawful arrest/excessive force, state torts, and an Equal Protection theory.
The magistrate judge recommended, and the district court granted, summary judgment for Cambridge and the officers: Title VII claims failed (no similarly situated comparator; legitimate nondiscriminatory reason—wrong patient; no evidence of hostile work environment); officers entitled to qualified immunity; any § 1983 claims also waived by Arucan’s plea-release.
The district court denied multiple requests to appoint counsel; the magistrate found no exceptional circumstances and that Arucan could articulate her claims.
On appeal, the Sixth Circuit affirmed in all respects: denial of counsel, summary judgment for defendants, enforceability of the plea-release as waiver, and dismissal of a belated Equal Protection (class-of-one) claim.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Appointment of counsel	Arucan argued she needed counsel due to complexity and possible incompetence to proceed pro se	Court argued no exceptional circumstances; plaintiff could articulate claims and case not unduly complex	Denial of counsel not an abuse of discretion; no fundamental unfairness
Title VII — disparate treatment	Arucan claimed discriminatory termination (race, sex, national origin); alleged others were treated better	Cambridge: no similarly situated employee; termination for treating wrong patient was legitimate nondiscriminatory reason	Summary judgment for Cambridge; no prima facie showing and no evidence of pretext
Title VII — hostile work environment	Arucan alleged hostile workplace based on discrimination	Cambridge: no evidence of severe or pervasive discriminatory conduct	Summary judgment for Cambridge; no evidence supporting hostile-environment claim
§ 1983 — unlawful arrest / excessive force & qualified immunity	Arucan argued officers arrested without probable cause and used excessive force	Officers: qualified immunity; moreover, plea agreement released claims against City and officers	Summary judgment for officers affirmed; claims waived by plea-release and qualified immunity alternative
Equal Protection (class-of-one)	Arucan argued a class-of-one claim (raised on appeal)	Defendants: Cambridge is not a state actor; no plausibly alleged comparator or irrational treatment by officers	Dismissal affirmed: claim implausible and not properly pleaded; cannot raise new claim on appeal

Key Cases Cited

Reneer v. Sewell, 975 F.2d 258 (6th Cir. 1992) (standard for reviewing denial of appointed counsel)
Lavado v. Keohane, 992 F.2d 601 (6th Cir. 1993) (appointment of counsel requires exceptional circumstances)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden-shifting framework for circumstantial Title VII claims)
Harris v. Forklift Sys., Inc., 510 U.S. 17 (1993) (hostile work environment standard)
White v. Baxter Healthcare Corp., 533 F.3d 381 (6th Cir. 2008) (standards for proving pretext in termination cases)
Town of Newton v. Rumery, 480 U.S. 386 (1987) (enforceability of plea agreements releasing claims against government actors)
Village of Willowbrook v. Olech, 528 U.S. 562 (2000) (class-of-one equal protection theory)
Davis v. Prison Health Servs., 679 F.3d 433 (6th Cir. 2012) (elements of class-of-one Equal Protection claim)
Paterek v. Vill. of Armada, 801 F.3d 630 (6th Cir. 2015) (Equal Protection requires state action)
Groening v. Glen Lake Cmty. Sch., 884 F.3d 626 (6th Cir. 2018) (de novo review standard for summary judgment)