Dewitt v. Proctor Hospital

Phillis Dewitt (plaintiff) worked for Proctor Hospital (Proctor) (defendant) from 2001 until 2005 as a clinical manager, supervising other nurses and staff. Phillis and her husband Anthony, who had prostate cancer, used Proctor’s health insurance. Proctor paid up to $250,000 out-of-pocket annually for each insured person. Beginning in 2003, Anthony’s annual cancer-treatment costs were $71,684, $177,826, and $67,281. Phillis’s supervisor, Mary Jane Davis, informed Phillis that a committee was reviewing Anthony’s medical expenses, and Davis asked whether the Dewitts had considered less-expensive hospice care. In May 2005, Davis informed Phillis and other clinical managers at a meeting that Proctor faced financial troubles that required creative cost-cutting efforts. In summer 2005, Phillis switched to a part-time schedule; Phillis claimed that she did so only on the condition that Proctor would continue covering her medical costs. Proctor fired Phillis in August 2005 without an explanation. Phillis paid for Consolidated Omnibus Budget Reconciliation Act (COBRA) insurance for herself and Anthony, which expired after 18 months, but Anthony died in August 2006. Phillis sued Proctor in federal district court, arguing in relevant part that her termination was association discrimination that had violated the Americans with Disabilities Act (ADA). Proctor moved for summary judgment, arguing that it had not terminated Phillis based on Anthony’s high medical costs. Proctor’s evidence was that (1) one or two other employees’ claims had exceeded the Dewitts’ claims in 2003, 2004, and 2005; (2) it had helped Phillis maintain her insurance coverage after she switched to a part-time schedule; and (3) firing Phillis did not actually cut costs, because Proctor incurred costs through Phillis’s COBRA insurance. The district court granted Proctor’s summary-judgment motion, and Phillis appealed.