Patricia Wheeler v. Georgetown University Hosp.
421 U.S. App. D.C. 165
| D.C. Cir. | 2016Background
- Wheeler, an African-American nurse, was hired as Clinical Nurse in 2006 at GUH’s 4 East unit; Hollandsworth became Clinical Manager in 2007 with hiring/termination control over RNs.
- In Dec 2009 Wheeler was floated to ICU; after shift, colleagues reported numerous alleged errors and neglectful care.
- Hollandsworth investigated; Wheeler provided written explanations in Jan 2010; Wheeler was terminated Jan 8, 2010 for alleged poor performance and policy violations.
- Hospital did not hire a replacement nurse after Wheeler’s termination; Wheeler filed EEOC charges in Jan 2010 and suit alleging race discrimination under Title VII.
- District Court granted summary judgment for Hospital in June 2014; Wheeler appealed arguing pretext and disparate treatment evidence required trial.
- Court reviews summary judgment de novo and assesses whether Hospital’s non-discriminatory reason could be pretextual based on evidence including comparators and discriminatory motive.
- Court remands for trial, finding genuine issues of material fact regarding comparators, their treatment, and whether Wheeler’s termination was racially motivated.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Wheeler’s comparator evidence could show pretext | Wheeler shows similarly situated white nurses treated more favorably | Hospital argues comparisons are not sufficiently similar or probative | Yes; issues of material fact exist as to comparators and pretext |
| Whether the proposed comparators were sufficiently similar in all relevant respects | Comparators shared job duties, supervisors, and discipline context | Disparities in supervision or unit could distinguish comparators | Yes; jury could find some comparators are similarly situated under Burley factors |
| Whether evidence supports an inference of racial discrimination rather than just poor performance | Disparate discipline pattern and shifting justification suggest discrimination | Discipline decisions based on performance were legitimate | Yes; record raises triable issues of pretext and discriminatory motive |
| Whether summary judgment was appropriate given competing inferences | Evidence viewed in Wheeler’s light favors discovery of pretext | Record shows legitimate reasons and no reasonable jury could find pretext | No; summary judgment improper; remand for trial |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (establishes burden-shifting framework for discrimination cases)
- Adeyemi v. District of Columbia, 525 F.3d 1222 (D.C. Cir. 2008) (limits the prima facie inquiry after employer proffers legitimate reason)
- Aka v. Washington Hosp. Ctr., 156 F.3d 1284 (D.C. Cir. 1998) (en banc; considers evidence of discrimination beyond prima facie case)
- Bar subscription not applicable, 450 U.S. 248 (1981) (Burdine; clarifies ultimate burden on plaintiff after pretext evidence)
- Holcomb v. Powell, 433 F.3d 889 (D.C. Cir. 2006) (summary judgment standard in discrimination cases; weighing evidence not done at SJ stage)