Plaintiff Christina Mitchell sued defendant Ascension Via Christi Hospital St. Teresa, Inc. in the United States District Court for the District of Kansas, raising claims of discrimination, retaliation, and hostile work environment under Title VII and the Americans with Disabilities Act (ADA). Before the court is Defendant’s motion to dismiss.
Statement of Facts
Christina Mitchell, an African American female with bipolar disorder, began working for Ascension Via Christi Hospital as a patient care technician on January 24, 2022. Her supervisor was Denise Dunn. Mitchell’s niece, Aveanna Amador, also worked at the hospital and lived with Mitchell’s mother. Around June or July 2022, Amador informed hospital staff about Mitchell’s bipolar disorder.
On February 25, 2023, Mitchell’s mother accused Amador of stealing, leading to an altercation between them. Shortly after, Amador moved in with Dunn. Rumors about the incident spread around the hospital. Mitchell complained about the rumors to another supervisor and the hospital’s “Associate Relations” department on March 3, 2023.
Following Mitchell’s complaints, Dunn allegedly began following Mitchell around the hospital, asking other nurses about Mitchell’s job performance, and making false statements about Mitchell leaving shifts early and refusing to work with Dunn. On March 30, 2023, Mitchell obtained a protection from stalking order against both Dunn and Amador.
On May 12, 2023, Mitchell was informed she would have to transfer to another hospital and was suspended based on a claimed incident where she supposedly physically attacked her niece. On May 16, 2023, Mitchell was terminated based on the alleged assault of Amador.
Legal Analysis
Title VII Discrimination: The court found that Mitchell failed to allege facts plausibly showing that others not in the protected class were treated more favorably than herself. Mitchell’s bare legal conclusion that non-African American employees were treated more favorably was insufficient to satisfy the fourth element of the prima facie case for her Title VII discrimination claim.
ADA Discrimination: The court determined that Mitchell failed to allege a single fact tying any alleged discrimination to her bipolar disorder. Without any factual allegations capable of plausibly supporting an ADA discrimination claim, the court granted the defendant’s motion to dismiss this claim.
Title VII Retaliation: The court ruled that Mitchell failed to establish that her belief that she was opposing discriminatory practices prohibited by Title VII was objectively reasonable. Based on the facts alleged in the complaint, no reasonable employee in Mitchell’s position would have believed the same.
ADA Retaliation: The court found that Mitchell failed to allege any facts connecting her coworkers’ workplace conduct to her alleged disorder. Without showing that the actions she complained of were discriminatory, Mitchell could not demonstrate that she engaged in protected activity by complaining to a supervisor and Associate Relations.
Hostile Work Environment Claims: The court determined that no alleged facts indicated that Dunn discriminated against Mitchell because of her race or disability, which is a fundamental element of both Title VII and ADA hostile work environment claims.
Request for Amendment: The court denied Mitchell’s request for leave to amend her complaint, finding that her perfunctory request failed to comply with the court’s rules governing amendment of pleadings.
The court granted the defendant’s motion to dismiss and dismissed all of Mitchell’s claims without prejudice.
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