Sibley Memorial Hospital v. Wilson

Verne Wilson (plaintiff) was a private-duty nurse. When patients at Sibley Memorial Hospital (Sibley) (defendant) required a private nurse, the hospital’s nursing office contacted a nursing registry. Patients were informed that the hospital and the registry cannot discriminate on the basis of race, age, or sex. When the registry received the request, it contacted a nurse who was available to work that day. The nurse reported directly to the patient’s room at the hospital. To discourage discrimination, if the patient rejected the nurse for any reason, the patient still had to pay the nurse for a full day’s work. Wilson alleged, however, that supervisory nurses at Sibley twice interfered and rejected him because he was male and the patients were female. Furthermore, he had never attended a female patient at Sibley, whereas the female nurses had male patients at Sibley. Wilson filed sex-based employment-discrimination complaints with the District of Columbia Council on Human Relations and the United States Equal Employment Opportunity Commission (EEOC). The EEOC found reasonable cause that Sibley violated Title VII of the Civil Rights Act of 1964 (Title VII). After conciliation failed, Wilson filed a complaint in district court seeking injunctive relief and monetary damages. Sibley argued there was no jurisdiction because it was not Wilson’s employer. The district court rejected Sibley’s jurisdiction argument and on its own initiative granted summary judgment for Wilson because Sibley, confident in its jurisdictional claims, had not properly disputed the substantive allegations. Sibley appealed.