United States District Court, N.D. Mississippi, Oxford Division
LAQUANIA M. WILLIAMS PLAINTIFF
BOARD OF COMMISSIONERS OF THE GREENWOOD LEFLORE HOSPITAL DEFENDANT
B. BIGGERS, JR. UNITED STATES DISTRICT JUDGE.
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.
and Procedural Background
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
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
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
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.
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.
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.
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.
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
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.
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.
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