University of Texas Southwestern Medical Center v. Nassar
An essential purpose of Title VII was to protect workers from retribution for complaining about workplace discrimination and ostracism. Cases reporting similar infractions have been expected, but one stood out (Griffin & Van Oort, 2013). The paper looks at the case of the University of Texas Southwestern Medical Center vs. Dr. Naiel Nassar, lists the ways in which the 1964 Act was broken, and comes to a well-thought-out conclusion based on the facts.
Dr. Naiel Nassar, a doctor from the Middle East, began working at Amelia Court Clinic in 1995 after being employed by the University of Texas Southwestern Medical Center (UTSW). In 2001, he returned from training and resumed working with Dr. Philip Keiser at UTSW, where he had previously worked (Cain, 2021). Beth Levine, Philip Keiser’s boss, began evaluating the plaintiff’s performance and billing efficiency. Dr. Levine also said that “Middle Easters are lazy.” notified Dr. Keiser, the complainant’s manager, of these remarks (Cain, 2021). Aside from that, the plaintiff learned that Dr. Levine had evaluated his performance more times than any other doctor in the world.
UTSW faculty denied the plaintiff’s request for a raise in 2006, after which the plaintiff resigned from the institution, alleging an unhealthy work climate and Levine’s unequal treatment. After leaving UTSW, the plaintiff applied for employment at the Amelia Court Clinic, where he was met with a barrage of hostility from faculty members (Cain, 2021). The plaintiff brought an action against UTSW under Title VII of the Civil Rights Act of 1964 for retaliation and dismissal in light of these incidents (Griffin & Van Oort, 2013). He contended that Dr. Levine had mistreated him because of his national origins (Cain, 2021). The plaintiff also filed a lawsuit, saying that he was treated unfairly and that his job was stressful, which was clear from the fact that he quit.
UTSW ensured that the institution and Parkland Hospital were linked, so the clinic could not hire doctors other than those employed by UTSW. According to Nassar, the emergency clinic hired physicians not affiliated with UTSW (Griffin & Van Oort, 2013). This is what sparked the first round of debate. Nassar was promised a position at Parkland Hospital if he resigned from the university, but only if he left. On June 3, 2006, Nassar was publicly offered a position in Parkland’s finance department. After receiving an offer of employment from the university, Nassar resigned before it could begin (Cain, 2021). In his letter of resignation, Nassar said that Dr. Levine’s actions were harassing and unfair, and he pointed to these as the main reasons he was leaving the company.
According to the plaintiff’s concerns, he was unjustly discriminated against based on his race. Title VII of the Civil Rights Act of 1964 prohibits job discrimination based on race, color, sexuality, religion, or nationality (Cain, 2021). According to Title VII, the defendant is liable for unfair employment practices since the plaintiff was denied his valid promotion request (Griffin & Van Oort, 2013). Because of how Dr. Levine hired people, which was unfair, the plaintiff lost out on job opportunities and was treated badly.
For the matter at hand, the question is whether or not a lawsuit claiming retribution under Title VII, Act of 1964, requires establishing that the employer’s retribution was the principal basis for the manager’s unfavorable acts. Although the Supreme Court of the U.S decided that Title VII business separation demands just establishing that discrimination is the primary cause, other elements such as the age discrimination statute may also play a role in such a case (Cain, 2021). UTSW countered the plaintiff’s allegation by focusing on interpreting the word “because” in Title VII’s language (Cain, 2021). As the defense argued, “because” indicates exclusivity, implying that the plaintiff must show that the employer’s negative actions were motivated only by retaliation to recover damages. Plaintiffs must also establish “but for” the manager’s discriminatory motivation and the alleged injury to the plaintiff (Cain, 2021). The defendant said that Title VII only covers claims of discrimination and not claims of retaliation against workers.
The plaintiff contended that harassment and retaliation are intimately linked and often brought up by complainants in discrimination-based litigation. Additionally, Dr. Nassar referred to the EEOC’s compliance handbook modifications (Cain, 2021). He argued that the EEOC revisions might be used for discriminatory and retaliatory claims against the defendant. The court ruled that a link between the claimed breach and the injury must be shown (Cain, 2021). According to this criterion of causation, if an action causes an occurrence, the event would not have happened without the action (Griffin & Van Oort, 2013). Because Congress has not included any language in the retaliation clause to contradict the above assumption, the criterion of causality is supported by Congress (Cain, 2021). The court ruled that under Title VII’s “but-for” causation, the plaintiff had to provide evidence to support the plaintiff’s retaliation allegations.
It was found that the plaintiff’s claims of constructive dismissal were not supported by sufficient evidence, as the Court of Appeal found. The Court of Appeals overturned the District Court’s decision to limit compensatory damages to $300,000, citing the preceding allegation (Cain, 2021). Section 2000e-2(m) defines motivating elements that lead to illegal employment behavior based on sex, color, ethnicity, nationality, or religion but does not include the retaliatory allegations (Cain, 2021). The court ruled that the plaintiff must show that the employer’s decision was not affected by anything other than the stated charge (Supreme Court of the United States, 2013). There were worries that lowering the causation requirement in Title VII could lead to more discrimination claims, which would make it harder for both employees and the courts to do their jobs. This is why the decision was made.
Title VII of the Civil Rights Act of 1964 prohibits discernment founded on race, ethnicity, nationality, religion, or sexual orientation in the workplace. For example, the Equal Employment Opportunity Commission (EEOC) is responsible for enforcing several acts and regulations that outlaw workplace abuse and harassment. The EEOC is responsible for implementing several laws, including Title VII. The EEOC’s Title VII statute prohibits companies from discriminating against their workers in any of the situations above (Supreme Court of the United States, 2013). Employers are not permitted by the Equal Employment Opportunity Commission (EEOC) to retaliate against employees who have complained or brought a case against discriminatory conduct. Furthermore, the legislation requires employers to make reasonable accommodations for job seekers’ and current employees’ religious beliefs. The plaintiff’s situation and the EEOC’s may be observed to be very similar in the preceding example (Supreme Court of the United States, 2013). The EEOC was called in to investigate when the plaintiff filed a discrimination-based retaliation claim.
The employer (UTWC) utilized Dr. Nassar’s resignation as an excuse to take retaliatory actions against him. As a rule, this should not be the case. When an employer victimizes against a worker based on their age, race, or ethnicity, the EOCC is the go-to organization. Also covered by Title VII are gender harassment and verbal and physical assault situations. The EOCC’s initial asset implements the EOCC’s core values.
References
Cain, T. (2021). Cause for Concern or Cause for Celebration? Did Bostock V. Clayton County Establish a New Mixed Motive Theory for Title VII Cases and Make It Easier for Plaintiffs to Prove Discrimination Claims? Seattle University Law Review, 45.
Griffin, T. A., & Van Oort, A. D. (2013). Supreme Court Decides University of Texas Southwestern Medical Center v. Nassar: Publications: Insights: Faegre drinker Biddle & Reath LLP. Publications | Insights | Faegre Drinker Biddle & Reath LLP.
Supreme Court of the United States. (2013). UNIVERSITY OF TEXAS SOUTHWESTERN MEDICAL CENTER v. NASSAR. Web.