Willie Betts v. Summit Oaks Hospital
687 F. App'x 206
| 3rd Cir. | 2017Background
- Betts, a Black registered nurse, was hired full-time at Summit Oaks Hospital in 2011 and was primarily assigned to Rehabilitation Unit (TU2) but was periodically floated to the Detoxification Unit (TU3).
- Betts alleged she was floated to TU3 more frequently than another full-time TU2 nurse and more often than per-diem/part-time nurses, and that the floating was race-based.
- She filed administrative charges with the New Jersey Division of Civil Rights and the EEOC in 2013, then sued pro se in federal court under Title VII in October 2014.
- The Hospital’s staffing policy authorized temporary reassignments (floating) based on census, patient acuity, and staff availability; Hospital evidence showed Betts’s title, pay, benefits, and terms of employment were unchanged.
- The District Court granted summary judgment for the Hospital, concluding Betts had not suffered an adverse employment action; the Third Circuit summarily affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether being repeatedly floated to TU3 constituted an adverse employment action under Title VII | Betts: frequent floating to TU3 imposed harsher work ("work of five people") and occurred more often to her because of race | Hospital: floating was routine per written policy and did not change title, pay, benefits, or significant job responsibilities | Court: Not an adverse employment action; summary judgment for Hospital affirmed |
Key Cases Cited
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden-shifting principles)
- Anderson v. Liberty Lobby, 477 U.S. 242 (evidentiary standard for genuine dispute at summary judgment)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (no genuine issue when record could not lead rational trier of fact to find for nonmovant)
- St. Mary’s Honor Center v. Hicks, 509 U.S. 502 (prima facie Title VII framework)
- Texas Dep’t of Cmty. Affairs v. Burdine, 450 U.S. 248 (prima facie burden-shifting in discrimination cases)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishing the McDonnell Douglas prima facie test)
- Burlington Indus. v. Ellerth, 524 U.S. 742 (definition of actionable adverse employment action)