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Joyner v. Sibley Memorial Hospital6/12/2003
Argued March 26, 2002
Jeanette Joyner contends that the trial court erred in entering summary judgment on some counts in her complaint and dismissing, without prejudice, the remaining counts in favor of appellees Sibley Memorial Hospital ("Sibley") and Jill Stanton. We affirm in part and reverse in part.
I. FACTUAL AND PROCEDURAL BACKGROUND
When the incidents underlying the claims in this case arose, Joyner was a part-time clerk typist in the Medical Records Department ("MR") and a part-time clerk typist in the Medical Staff Privileges Department ("MSP") at Sibley. This appeal arises out of a series of events involving Joyner and Stanton, who was an employee of the hospital and Joyner's then supervisor in MR.
A. Facts
Joyner is an African-American female who was sixty-one years of age at the time of the events giving rise to this action. She began her employment with Sibley in 1977 as a receptionist in MR. In 1981, Joyner transferred to a position of clerk typist in MSP. In 1992, Sibley underwent some administrative reorganization, and Joyner's post in MSP was reduced to part-time. However, she was also reassigned to part-time duties in her former department as clerk typist in MR, thus retaining a full-time status overall.
In November of 1996, there was a change in the management of MR, and Stanton assumed the position of Director. Shortly thereafter several incidents occurred, which Joyner asserts as the basis of her claims here. On December 9 of that year, Stanton issued a verbal reprimand to Joyner based upon a complaint Stanton had received regarding Joyner's allegedly inappropriate response to a request for a patient's file from a doctor's office. On December 30, Joyner received her 1996 performance evaluation, which reflected a lower score than she had received in previous years from other supervisors. This evaluation also deferred final disposition of Joyner's evaluation for ninety days, during which she was to complete a course on WordPerfect.
On January 9, 1997, Joyner was given an assignment, which she called "unusual," to obtain a large number of files from an adjacent building and then return the files once they had been properly coded. As a result of a report that Joyner had left those files unattended, Stanton verbally admonished her. On January 27, Joyner again received a verbal reprimand, her second, because she repeatedly punched in on the time clock more than a few minutes prior to her scheduled start time in violation of the procedures set forth in a recently circulated memorandum applicable to all employees.
On January 31, 1997, Joyner submitted a written response in her defense to the verbal reprimand dated December 9, 1996 relating to the complaint regarding an allegedly inappropriate response to a doctor's office's request for a patient's files. She maintained that the incident that precipitated the reprimand was simply a misunderstanding. She indicated that the person to whom she released the files, the husband of the patient whose files were the subject of the request, was satisfied with Joyner's performance. To support that claim, she submitted a commendation letter from the husband. Joyner's response, however, revealed her possible violation of hospital policy in two ways: release of confidential medical records without signed authorization from the patient, and solicitation of a letter of commendation from patients or their families. As a result, Stanton drafted a written reprimand on February 3, 1997 setting forth the two violations, and scheduled a meeting with Joyner for February 7, 1997.
The meeting was held in Stanton's office. At that meeting, Stanton charac
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