Courtnay Bell v. Baptist Health, No. 22-2057 (8th Cir. 2023)
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Plaintiff appealed the district court’s grant of summary judgment to Defendant, Baptist Health, on her sex-discrimination, retaliation, hostile work environment, constructive-discharge, and negligent-retention claims. After the individual defendant was dismissed as a defendant, Baptist Health moved for summary judgment, and the district court granted its motion.
The Eighth Circuit affirmed. The court first explained that here, Plaintiff presented no evidence that Baptist Health intended to force her to quit. Rather, the record indicates that Baptist Health tried to retain Plaintiff by giving her paid administrative leave, offering to relocate her to a different location, and offering to transfer her to a new department. Thus, the district court did not err in granting summary judgment to Baptist Health on this claim.
Second, the court held that Plaintiff’s sex-discrimination and retaliation claims fail because she has not suffered an adverse employment action. Baptist Health offered for Plaintiff to keep her same job at any one of three locations or to transfer departments. The court wrote that Plaintiff has not shown that transferring to another department would produce a material employment disadvantage.
Third, the court found that the district court did not err in granting summary judgment to Baptist Health on this claim because there is no evidence that the alleged discrimination was based on sex. Finally, the court found that the evidence does not suggest that Baptist Health subjected her to any unreasonable risk of harm.
Court Description: [Gruender, Author, with Benton and Shepherd, Circuit Judges] Civil case - Employment discrimination. Plaintiff failed to establish constructive discharge; plaintiff's sex-discrimination and retaliation claims both fail because she failed to create a genuine issue of material fact about whether she suffered an adverse employment action; plaintiff's claim of hostile work environment failed because there was no evidence that the alleged discrimination by the doctor in question was based on sex; on this record, the district court did not err in granting defendant summary judgment on plaintiff's Arkansas state-law claim for negligent-retention.
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