Zayas v. Rockford Memorial Hospital
2014 U.S. App. LEXIS 1875
| 7th Cir. | 2014Background
- Zayas worked as an ultrasound technician at Rockford Memorial Hospital from Nov 1999 to Apr 2011.
- Her supervisor Griesman was responsible for hiring and terminating her.
- She is Puerto Rican and was 55 at termination, the oldest technician in the department.
- Plaintiffs asserted Title VII national-origin discrimination, hostile work environment, and ADEA claims.
- Zayas was discharged April 22, 2011 for sending emails deemed disrespectful by Griesman, despite warnings.
- District court granted summary judgment for the Hospital on all claims; the Seventh Circuit reviews de novo.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| May indirect proof support discrimination claims? | Met prima facie and showed pretext via performance scores. | Did not show meeting expectations when fired; no valid comparator. | No prima facie case; summary judgment for Hospital affirmed. |
| Was a hostile-work-environment claim shown based on national origin? | Multiple incidents tied to national origin show harassment. | incidents insufficiently connected to ethnicity; isolated or unrelated events. | Hostile environment claim failed; summary judgment affirmed. |
| Was there pretext to support discrimination/termination? | Emails were pretext; performance reviews show fit with expectations. | Griesman believed the emails were inappropriate; pretext denied. | No evidence of pretext; termination based on the emails; summary judgment affirmed. |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (Supreme Court 1973) (establishes indirect-discrimination framework)
- Peters v. Renaissance Hotel Operating Co., 307 F.3d 535 (7th Cir.2002) (broader employer-expectations analysis in discrimination cases)
- Naficy v. Ill. Dep’t of Human Servs., 697 F.3d 504 (7th Cir.2012) (McDonnell Douglas prongs in state actor context)
- Adams v. Wal-Mart Stores, Inc., 324 F.3d 935 (7th Cir.2003) (circumstantial evidence requires directntive inference of motive)
- Beamon v. Marshall & Ilsley Trust Co., 411 F.3d 854 (7th Cir.2005) (hostile environment framework and discriminatory motivation)
- Harris v. Forklift Sys., 510 U.S. 17 (1993) (objective/severity standard for hostile environment claim)
- Filipovic v. K & R Express Sys., Inc., 176 F.3d 390 (7th Cir.1999) (hostile work environment requires more than petty harassment)
- Oest v. Ill. Dept. of Corr., 240 F.3d 605 (7th Cir.2001) (uncorroborated generalities insufficient for Title VII claim)
- Ransom v. CSC Consulting, Inc., 217 F.3d 467 (7th Cir.2000) (pretext inquiry focuses on reason for action, not fairness)
- Smiley v. Columbia College Chi, 714 F.3d 998 (7th Cir.2013) (standard for de novo review of summary judgment in employment cases)