Sixth Circuit Finds That Employer Who Terminated Employee Due to Her Romantic Relationship Is Not Liable in Stevens v. Saint Elizabeth Medical Center, Inc.
In the recent case Stevens v. Saint Elizabeth Medical Center, Inc., the Sixth Circuit Court of Appeals ruled that terminating an employee after discovering a consensual, but inappropriate, workplace relationship that has soured is not grounds for wrongful termination or hostile work environment.
The case involved a nurse, Caroline Stevens, who worked for Physician Associates, LLC and Patient First Physicians Group, the latter of which was later acquired by Saint Elizabeth Medical Center. Stevens served as a nurse and personal assistant for Dr. Donald Saelinger, the Chief Executive Officer for Patient First Physicians Group. During many of the years they worked together, Stevens and Saelinger had a romantic relationship, until Stevens broke it off in 2009 when she learned that Saelinger had not divorced his wife.
Stevens later filed a complaint that her site supervisor, Gary Brown, was pressuring her to take a new position after Saelinger expressed a desire to reduce his patient load. She noted that no patients had been transferred to other doctors. Brown was aware that Stevens and Saelinger used to be in a relationship. Investigation into the complaint revealed that Stevens and Saelinger not only had an affair, but that they also had several sexual episodes on office grounds. As a result, their employer gave them both the option of resigning or being terminated. Saelinger resigned, while Stevens was terminated. Stevens then filed a lawsuit against Saelinger, Physician Associates, Patient First Physicians Group, and Saint Elizabeth Medical Center, alleging sexual harassment under Title VII, the Kentucky Civil Rights Act, wrongful termination (retaliation) and fraud. The defendants filed a motion for summary judgment and the district court ruled in their favor. Stevens then appealed to a three-judge panel on the Sixth Circuit to review the case.