Lane v. Riverview Hosp.

Lane, an African-American, began working as a hospital security guard in 1999. He had an unblemished employment record until August 2012, when a 17‐year‐old male autistic patient started hitting and kicking his caregivers. Health care professionals, afraid to approach the patient or enter the room, summoned security. Lane responded and saw the patient kick a staff member in the back. Lane tried to restrain the patient, who tried to bite him and spit in Lane’s mouth. Lane slapped him in the face. The patient settled down. Lane filed reports explaining why he thought the slap was justified with the hospital and with the Sheriff’s Department, where he had status as a special deputy as a condition of his job. The recipients concluded he had shown poor judgment. The hospital’s director of human resources recommended that Lane’s employment be terminated. After a consultation with the Sheriff’s Department, the hospital told Lane that if he did not resign, he would be fired. He resigned. After exhausting EEOC remedies, Lane filed suit for race discrimination under Title VII, 42 U.S.C. 2000e–2(a), and 42 U.S.C. 1981. The Seventh Circuit affirmed summary judgment in favor of the hospital. Lane intentionally struck a patient; termination was a reasonable response. “Lane’s effort to put together a mosaic of circumstantial evidence of race discrimination” did “not hold together sufficiently to present a genuine issue of material fact.” View "Lane v. Riverview Hosp." on Justia Law