Hospital Employee Established Prima Facie Case Of Retaliation

Denying the defendants’ motion for summary judgment, the United States District Court held that the plaintiff, an African-American hospital employee, had established a prima facie case of retaliation under Title VII and the Massachusetts civil rights statute. The employee produced evidence she wrote a letter to the acting director of the hospital's facilities management department claiming the hospital owed her two years of accrued call-back pay. The letter could be fairly read as an opposition to allegedly unlawful employment practices, and the employee suffered one or more adverse employment actions as a result thereof. A fact issue existed as to whether the employee's complaints of discrimination caused her to be singled out as a target of retaliation.

Booker v. Massachusetts Dept. of Public Health

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