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Williams v. Board of Commissioners of Greenwood Leflore Hospital

United States District Court, N.D. Mississippi, Oxford Division

May 10, 2017




         Presently before the court is the defendant's motion for summary judgment. Upon due consideration of the motion, response, exhibits, and supporting and opposing authority, the court is ready to rule.

         Factual and Procedural Background

         The plaintiff, Laquania Williams, brings this action against her former employer, Greenwood Leflore Hospital (“GLH”), alleging violations under 42 U.S.C. § 12101 for claims arising under the Americans with Disabilities Act (“ADA”) and the Americans with Disabilities Amendments Act (“ADAA”). She further alleges violations under 42 U.S.C. § 2601 for claims arising under the Family and Medical Leave Act (“FMLA”).

         Williams contends that were it not for her alleged disability, suffering from back problems, that GLH would not have terminated her employment. Williams further argues that GLH wrongfully interfered with her FMLA rights by not providing her with FMLA leave. Williams additionally asserts, in the alternative, that her termination was an act of retaliation because of her request for FMLA leave and/or her taking FMLA leave.

         Williams alleges that she suffered back problems for years before finally undergoing a successful surgery in 2009. In 2013, however, Williams reinjured her back while working at Parkwood, a behavioral healthcare center. On August 28, 2013, after the aforementioned injury, GLH hired Williams as a registered nurse assigned to the hospital's Holding Unit. The Holding Unit is a facility within the hospital where individuals are housed for evaluation pursuant to a court order.

         Williams worked without issue until sometime in January of 2014 when she began experiencing back pain. During this time, her primary care physician referred her to a specialist who ultimately recommended that she undergo another surgery. When she spoke with GLH's human resources department, Williams alleges she was informed that she would lose her job if she had the surgery. Williams, therefore, chose not to undergo surgery at that time.

         Over a year later, in July of 2015, Williams again began experiencing back pain and decided she needed to seek medical attention. On July 15, 2015, Williams requested the day off to see a doctor. Williams' supervisor, Rebecca Edwards, allegedly responded to this request by explaining that if she did take off, she would likely be fired. Williams, however, believed that she had sick leave remaining, and had someone else cover her shift that day and went to seek treatment.

         Williams sought treatment from Dr. Wells, her long-time physician, and he referred her to a neurologist. Dr. Wells also provided a doctor's excuse and advised that he felt it was best that Williams not return to work until after her appointment with the neurologist. Later that day, Williams presented the excuse to GLH and expressed her desire to take FMLA leave. GLH informed Williams that she did qualify for FMLA leave and gave her the requisite paperwork to be completed and submitted within fifteen days.

         Pursuant to Dr. Wells' instruction, Williams remained off work until her appointment with the neurologist, Dr. Eckman, on July 22, 2015. Williams submitted the completed FMLA paperwork and applied for short-term disability later that day. The following day, July 23, 2015, Williams returned to work, and, at the end of her shift, GLH terminated her employment. GLH explained to Williams that she was being fired because it believed she had allowed an unauthorized person to administer a medical injection.

         The incident to which GLH was referring occurred in June of 2015. John Doe was a patient in the holding unit from June 17 through June 30. Doe acted in an especially difficult manner on June 21, such that Williams felt it necessary to give a medical injection to calm him down. Williams called security for help and, because of Doe's erratic behavior, she allowed another GLH employee, Talmidge Meeks, to administer the medication.

         Meeks was enrolled in a Registered Nursing program at an affiliated school of nursing and was participating in GLH's “Nurse Extern” program at the time. Pursuant to a hospital policy allowing nurse externs to engage in such actions under the direction of an instructor, Williams believed Meeks was authorized to administer the injection.

         GLH, however, asserts that on the date in question and in that particular unit of the hospital, Meeks was not a nurse extern. Instead, according to GLH, Meeks was working solely as a Mental Health Technician (“MHT”) in the holding unit that day and, consequently, was unauthorized to administer such medications.

         Following her termination, Williams filed a charge with the Equal Employment Opportunity Commission and, after exhausting her administrative remedies, filed the instant suit. GLH now moves for summary judgment and argues that Williams has ...

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