Chaney v. Plainfield Healthcare Center

Brenda Chaney (plaintiff) worked as a certified nursing assistant (CNA) at Plainfield Healthcare Center (Plainfield) (defendant). Plainfield resident Marjorie Latshaw informed Plainfield that she did not want care from Black CNAs. Plainfield had a policy of complying with residents’ racial preferences. Consequently, on the daily assignment sheets provided to CNAs, Plainfield noted Latshaw’s preference. Afraid of being fired, Chaney, who was Black, honored Latshaw’s request. However, the race-based limitations on Chaney’s work caused her emotional upset. That upset was heightened by comments from White coworkers taunting Chaney about her race’s impact on her ability to provide care. Although Plainfield took measures to discourage the worst comments, coworkers continued to regularly reference Chaney’s inability to care for certain residents. Sometime later, Plainfield fired Chaney. Chaney then sued Plainfield, alleging that Plainfield violated Title VII of the Civil Rights Act of 1964 by (1) complying with residents’ racial preferences and creating a hostile work environment and (2) firing Chaney because of her race. Regarding the hostile-work-environment claim, Plainfield argued that honoring residents’ racial preferences was required to comply with federal and state laws regarding the provision of medical care. The district court agreed, granting summary judgment in Plainfield’s favor on the hostile-work-environment claim. Chaney appealed.