Nnadozie v. Genesis Healthcare Corp.

Emanuella Nnadozie, Perpetua Ezeh, and Sunday Aina (the nurses) (plaintiffs) worked at Patapsco Valley Center (Patapsco), a Maryland nursing home managed by Genesis Eldercare Network Services (Genesis) and staffed by 9109 Liberty Road Operations, LLC (Liberty) (defendants). All three nurses were of African origin and had a history of performance issues. In late 2010, Genesis appointed Mary Hochradel as Patapsco’s administrator and Denise Zimmerman as its director of nursing. Tension arose between Zimmerman and Nnadozie when Zimmerman pressured Nnadozie to discipline African staff and gave Nnadozie poor performance evaluations, culminating in a final written warning. Nnadozie resigned and filed a charge with the Equal Employment Opportunity Commission (EEOC), alleging discrimination based on race and national origin. Nnadozie subsequently sued Genesis and Liberty, asserting constructive-discharge, hostile-work-environment, and retaliation claims under 42 U.S.C. § 1981 and Title VII of the Civil Rights Act of 1964 (Title VII). Nnadozie’s complaint referenced only national-origin discrimination. Shortly after Zimmerman’s arrival at Patapsco, Ezeh began complaining about disrespect from Zimmerman, and Zimmerman began giving Ezeh poor performance reviews. After Ezeh took medical leave, Genesis refused to rehire her, citing performance infractions. Ezeh filed an EEOC charge alleging national-origin discrimination and retaliation. Ezeh then filed suit, asserting hostile-work-environment and retaliatory-termination claims under § 1981 and Title VII. Ezeh’s complaint alleged both racial and national-origin discrimination and referenced statements by Zimmerman that she was worried about Africans killing her and using voodoo against her. Aina was issued a final warning from Zimmerman regarding his caregiving and then suspended without pay. He filed an EEOC charge alleging the suspension resulted from national-origin discrimination. Shortly after returning to work, Aina was terminated for failing to report a bruise on a patient. Aina filed suit, asserting hostile-work-environment and retaliatory-discharge claims under § 1981 and Title VII based on national-origin discrimination. He claimed that Hochradel had said she wanted to fire him because Patapsco had “a lot of Africans.” The district court granted summary judgment in Genesis’s and Liberty’s favor on all claims. The nurses appealed.