Karon Jackson v. VHS Detroit Receiving Hospital
814 F.3d 769
| 6th Cir. | 2016Background
- Karon Jackson, a female mental health technician (MHT), worked at Detroit Receiving Hospital’s Crisis Center from 1998 until termination after a September 6, 2013 patient-discharge error: she and an RN escorted the wrong patient out without checking the patient ID band; the patient returned hours later unharmed.
- DRH terminated Jackson for violating two “major infractions” in its policy (endangering patients and violating health/safety standards); four female supervisors signed the termination memo.
- Jackson had strong prior performance reviews and no prior discipline; two male MHTs—Ronald Duncan and Lester Little—committed serious infractions (Duncan once walked out the wrong patient while under a last-chance agreement; Little failed to search a patient who had three knives) but were not terminated.
- Jackson sued under Title VII, claiming sex discrimination based on differential treatment compared to Duncan and Little; the district court granted summary judgment for DRH, finding no evidence of pretext.
- The Sixth Circuit reversed, holding Jackson established a prima facie case and that a reasonable jury could find DRH’s stated reasons for termination pretextual when facts are viewed in Jackson’s favor.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Jackson established a prima facie Title VII sex-discrimination claim | Jackson: she is female, was terminated, was qualified, and similarly situated male MHTs (Duncan, Little) were treated more favorably | DRH: comparators’ misconduct not sufficiently similar; Jackson’s error was more egregious | Held: Jackson met the prima facie burden — comparators were similar enough to raise an inference of discrimination |
| Whether DRH offered a legitimate non-discriminatory reason for termination | Jackson: DRH’s reason (greater egregiousness) is pretext | DRH: Jackson’s patient was suicidal and meeting had emphasized ID checks — justified harsher discipline | Held: DRH proffered a reason, but factual disputes permit a jury to find pretext |
| Whether comparators’ differences defeat inference of discrimination at the pretext stage | Jackson: differences are not dispositive; context supports disparate treatment | DRH: Duncan had prior discipline/last-chance agreement and was excused by video; Little’s infraction differed (search vs. ID) | Held: factual differences do not compel judgment for DRH; a jury could reasonably reject DRH’s explanations |
| Whether workplace demographics and decisionmakers negate inference of sex bias | Jackson: being only female MHT supports an inference that MHTs were preferred male | DRH: majority of other staff were female and decisionmakers were female | Held: demographics and decisionmakers’ sex do not preclude inference of discrimination; viewed favorably to Jackson they support her claim |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden‑shifting framework for circumstantial discrimination claims)
- Texas Dep’t of Cmty. Affairs v. Burdine, 450 U.S. 248 (1981) (prima facie purpose and burden allocation under McDonnell Douglas)
- Oncale v. Sundowner Offshore Servs., Inc., 523 U.S. 75 (1998) (same‑sex discrimination claims cognizable under Title VII)
- Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (2000) (pretext evidence may permit judgment for plaintiff)
- Mitchell v. Toledo Hosp., 964 F.2d 577 (6th Cir. 1992) (factors for determining whether employees are similarly situated)
- Provenzano v. LCI Holdings, Inc., 663 F.3d 806 (6th Cir. 2011) (summary judgment and the McDonnell Douglas inquiry)
- Dews v. A.B. Dick Co., 231 F.3d 1016 (6th Cir. 2000) (three‑part test for showing pretext)
- Cline v. Catholic Diocese of Toledo, 206 F.3d 651 (6th Cir. 2000) (evaluation of evidence at summary judgment in discrimination cases)