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Wellborn v. Spurwink/Rhode Island4/25/2005
The defendant, Spurwink/Rhode Island, appeals from a Superior Court judgment in favor of the plaintiff, Angelina M. Wellborn. Spurwink argues that the trial justice should have granted its motion for judgment as a matter of law pursuant to Rule 50 of the Superior Court Rules of Civil Procedure, or in the alternative, that the trial justice should have granted Spurwink's motion for a new trial pursuant to Rule 59. This case came before the Court for oral argument on March 7, 2005, pursuant to an order directing all parties to appear and show cause why the issues raised in this appeal should not summarily be decided. After considering the arguments of counsel and examining the memoranda filed by the parties, we are of the opinion that cause has not been shown, and we will proceed to decide the case at this time. For the reasons stated below, we deny the defendant's appeal.
Facts and Procedural History
Beginning in early September 1997, until the events giving rise to the underlying case, Angelina Wellborn worked as a residential instructor at the Brook Manor Group Home in Hope Valley, Rhode Island. Brook Manor is a group home operated by defendant corporation, Spurwink/Rhode Island, for developmentally disabled adults, where, at the time of Wellborn's employment, there resided four older, nonverbal, disabled women. As a residential assistant, Wellborn's job consisted of such tasks as performing light household chores, assisting the residents with physical and occupational therapy, and taking the residents on community outings. Wellborn testified that during her employment by Spurwink, she worked approximately twenty-eight hours per week, as a part-time employee. At the outset of her employment, she informed her superiors of her desire for a full-time position when one became available.
In June 1998, Wellborn, then five months pregnant, was informed by her superior, program manager Gretchen Dante, that she needed to get a doctor's note detailing any pregnancy-related job restrictions. Soon after, Wellborn visited her obstetrician, Dr. David Small, and received a note explaining her medical status. The note, addressed to "Whomever," stated the following:
"Ms. Angelina Wellborn is currently pregnant with expected due date of 31 October, 1998. Angie is capable of doing the routine functions of her job except that she should not be lifting [greater than] 20 lbs without assistance or lifting patients. Angie should not be involved with physically restraining group home patients. She should not be working on ladders/stools or overhead. Light cleaning chores ok."
Wellborn gave this note to Dante within a week of receiving it, and heard nothing further regarding her duties at Brook Manor. Nearly two months later, however, a full-time position became available, but it was offered to a different employee. At nearly the same time, in early September, Wellborn was informed by Dante that she had to begin her maternity leave immediately because of the restrictions detailed in the doctor's note. Wellborn later testified that Dante considered her to be a "liability" to the company due to those restrictions.
Despite Wellborn's objections to leaving, and her insistence that remaining on the job would not put her health, the health of her unborn child, or the health of the Brook Manor residents in jeopardy, Spurwink insisted that she take her leave immediately. Wellborn testified that her superiors stressed that her doctor's note was the reason for their action. Wellborn further testified that she never, before or during her pregnancy, needed to physically restrain a resident, and that there was always at least one other worker on duty to provide assist
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