Reversal: Former St. Mary’s employee loses claims against her termination

The Indiana Court of Appeals reversed and remanded the denial of a hospital’s motion for judgment against a former employee terminated for unethical behavior when it found the hospital was entitled to judgement due to the lack of genuine issues of material fact.

Elizabeth Miranda was a nurse liaison in the emergency department at St. Mary Medical Center, Inc., in Hobart, In her role, Miranda was required to instruct and inform the registration employee concerning the patient’s chief complaint. Once the patient arrives, registration employees are required to input the patient’s information into the hospital’s system.

In July 2015, Miranda was suspended and ultimately terminated from her position for allegedly asking a registration employee to delay inputting the arrival time of a patient, therefore delaying their treatment.

Miranda then filed a complaint for damages and injunctive relief against Community Foundation of Northwest Indiana, Inc., St. Mary Medical Center, Inc., and Rebecca Iwanus, Miranda’s supervisor. Among other things, Miranda alleged breach of contract and wrongful termination, negligence, defamation, libel and slander against all three defendants.

Defendants filed a motion for summary judgment in January 2018 but were denied when Lake Superior Judge Calvin D. Hawkins ultimately certified the order for interlocutory appeal sua sponte. However, the Indiana Court of Appeals reversed and remanded that decision in Community Foundation of Northwest Indiana, Inc., St. Mary Medical Center, Inc., and Rebecca Iwanus v. Elizabeth A. Miranda, 18A-PL-1458, finding no genuine issues of material fact exist and that the defendants were entitled to judgment as a matter of law.

The appellate court agreed with the defendants’ first assertion that Miranda was an at-will employee who was ultimately terminated due to performance issues. It found Miranda did not have a contract for employment, despite her reliance on St. Mary’s employee contract and her offer letter, noting that the handbook specifically stated its contents should not be construed as a contract.

Additionally, the appellate court found fault with Miranda’s defamation, libel and slander claims, concluding that any statements made in the corrective action report and emails sent between St. Mary’s employees clearly demonstrated the statements were protected by qualified privilege.

“The designated evidence demonstrates that St. Mary’s kept these communications within the system,” Judge Elizabeth Tavitas wrote. “Accordingly, Defendants proved that the qualified privilege protected the communications Miranda contends are defamatory.”

Lastly, the appellate court found Miranda could not succeed with her injunctive relief claim as a result of the Defendants’ entitlement to summary judgment based on the designated evidence.

“We note that the trial court issued a brief order denying summary judgment and certified the order for interlocutory appeal sua sponte to ‘allow’ this court to ‘deal with’ the legal issues surrounding summary judgment,” Tavitas added. “We are perplexed by the trial court’s statement that he would ‘give [this court] work[,]’ shirking its duties and essentially punting to this court to serve as the court of first review. That is not the role of our court. The trial court erred by denying Defendants’ motion for summary judgment.”