Watson v. Heartland Health Labs, Inc., No. 14-2402 (8th Cir. 2015)
Annotate this CaseHeartland provides laboratory services to long-term healthcare facilities. Watson, an African-American woman, was a route phlebotomist, traveling to several facilities, drawing blood from patients, and returning to the lab to process the samples. As a new employee, Watson was subject to a 90-day probationary period. Watson's route included Plaza Manor, where she was assigned to draw blood from Ramsey. While Watson was attempting to draw Ramsey's blood, he touched Watson’s inside thigh and moved his hand upward. Watson told Ramsey to stop and brushed his hand away. When Ramsey touched her "crotch area," Watson knelt down to draw Ramsey's blood. Ramsey put his hand on her side. After she stopped attempting to draw blood, Ramsey "grabbed the back of [Watson's] neck to try to kiss [her]." Watson left and reported the incident to Heartland, which ensured that she never provided services for Ramsey again, but denied her request for a route change. Watson continued to visit Plaza Manor. Ramsey verbally assaulted Watson, making racial and sexually derogatory remarks. After the seventh incident, Watson missed three days of work. Under Heartland's policy, an employee is considered to have voluntarily abandoned her job after two consecutive days of absence without properly notifying Heartland. Heartland left multiple voicemail messages. The Eighth Circuit affirmed summary judgment rejecting her claims of hostile work environment, constructive discharge, and retaliation under the Missouri Human Rights Act.
Court Description: Smith, Author, with Loken and Colloton, Circuit Judges] Civil case - Employment discrimination. The district court did not err in finding a nursing home patient's conduct towards plaintiff, an employee of a service performing blood work at the home, was not so severe that it rose to the level of actionable hostile work environment sexual harassment; since the conduct did not affect a term, condition or privilege of plaintiff's employment, defendant was entitled to judgment as a matter of law on plaintiff's hostile-work environment claim; a reasonable person would not have found plaintiff's work environment intolerable and defendant was entitled to judgment on plaintiff's claim for constructive discharge; plaintiff did not suffer any adverse action as a result of her complaints against the patient nor did she show any causal connection between any action defendant took and the complaints she made.
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