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Ehling v. Monmouth-Ocean Hospital Service Corp.

872 F. Supp. 2d 369 (2012)

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Ehling v. Monmouth-Ocean Hospital Service Corp.

United States District Court for the District of New Jersey

872 F. Supp. 2d 369 (2012)

Facts

Deborah Ehling (plaintiff), a registered nurse and paramedic, worked for the Monmouth-Ocean Hospital Service Corporation (MONOC) (defendant). In 2008, approximately four years into her tenure with MONOC, Ehling became the acting president of the Professional Emergency Medical Services Association (union), a local union. Ehling proactively sought to protect the interests of the union’s members and filed numerous labor charges and complaints against MONOC. According to Ehling, MONOC began a pattern of retaliatory conduct when she became the union president that eventually led to her termination in 2011. Ehling alleged that in 2009, a MONOC supervisor coerced a subordinate who was Ehling’s Facebook friend to show the supervisor Ehling’s Facebook posts. Ehling was Facebook friends with numerous coworkers but not with any member of MONOC’s management, and Ehling’s privacy settings on Facebook were such that only her friends could see her posts. One of the posts viewed by the MONOC supervisor concerned a shooting that occurred at the Holocaust Museum in Washington, D.C. Ehling’s post suggested that the paramedics who responded at the scene should not have saved the shooter’s life. MONOC wrote to the state nursing and paramedic licensing boards about Ehling, expressing concern that her post displayed a lack of concern for patient safety. Ehling filed suit against MONOC, alleging, among other things, that MONOC invaded her privacy by accessing the Facebook post. MONOC moved to dismiss Ehling’s amended complaint.

Rule of Law

Issue

Holding and Reasoning (Martini, J.)

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