Hassen v. Ruston Louisiana Hospital Co., No. 18-30856 (5th Cir. 2019)
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The Fifth Circuit affirmed the district court's grant of summary judgment for the hospital in an action brought by plaintiff, alleging Title VII race discrimination. Applying the McDonnell Douglas burden-shifting framework, the court held that the hospital offered a legitimate nondiscriminatory explanation for not hiring plaintiff (she never applied for a full time position), and plaintiff failed to show that the hospital's stated explanation was mere pretext.
In regard to plaintiff's termination claim, plaintiff failed to show that she was treated differently from similarly situated white nurses. Even if plaintiff had made a prima facie case, the hospital met its burden by explaining that plaintiff's schedule at her new full-time job elsewhere conflicted with the only shifts available to PRN nurses. Furthermore, plaintiff identified no evidence that would prove that the hospital's explanation was pretext.
The court issued a subsequent related opinion or order on August 1, 2019.
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