Loyd v. Saint Joseph Mercy Oakland, No. 13-2335 (6th Cir. 2014)Annotate this Case
Loyd, an African-American woman, began working as a hospital security guard in 1986. In 2001 Loyd had a written warning for failing to help restrain a patient because she questioned the authority of the medical staff to have the patient restrained. Loyd received a warning in 2004 for refusing to work overtime. In 2010 Loyd left work due to illness without first obtaining permission, and, another time, was found on the porch of a nearby house while on duty. The hospital placed Loyd on final-written-warning status. Loyd was dispatched on June 16, 2011 to a room containing a combative female psychiatric patient. Instead of helping to restrain the patient, according to the hospital, Loyd told the patient that she could leave if she had been admitted for a drug-related or alcohol-related (not psychiatric) reason and demanded to see the admissions paperwork. Loyd’s actions agitated the patient, who tried to pull an IV out of her arm. Other guards restrained the patient. Loyd admits much of the incident, but denies that she failed to assist. The hospital conducted an internal investigation, after which it terminated Loyd’s employment. Loyd filed a union grievance, which was denied. The union declined to seek arbitration. The hospital hired a 39-year-old African-American woman for the position. After filing charges of discrimination with the EEOC and Michigan Department of Civil Rights, Loyd filed suit. The district court granted the hospital summary judgment on all claims. The Sixth Circuit affirmed.