Case Analysis: Christine Brooks v. Cooke County Hospital District

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Case Analysis #3

Case Analysis #3

Christine Brooks v. Cooke County Hospital District


Christine Brooks was placed on probation in February 1994, after working for ten years with the Cooke County Hospital District (“CCHD”), for exhibiting poor work attitude, breaching patient confidentiality, and engaging in personal business at work. CCHD terminated Brook’s employment, while she was on probation, because of additional policy violations. Brooks filed suit against CCHD on December 28, 1994.

This case is related to the employer-employee relationship and at-will employment. The big issues in this case seem to be:

  • Did a contract exist between Brooks and CCHD, as opposed to a traditional at-will employment?
  • Was there a violation of either the contract or the at-will employment doctrine by CCHD?
  • Was there a serious violation of policy by Brooks?

The sub issues are:

  • Was there any discrimination or retaliation against Brooks?
  • Was Brooks being penalized twice for the same cause?
  • Was Brooks negligent in discussing the situation in an open setting?

Christine Brooks’ case

Christine Brooks had been employed with CCHD for almost ten years. In 1994 she was terminated while on probation. The following text attempts to analyze Brooks’ position and the approach that she should take to make her case against CCHD. Brooks’ case should focus on proving that her status with CCHD was not at-will and that CCHD broke a contract that they had. Given that the burden of proof was on Brooks’, here is how she should analyze and start presenting her case:

Given the sequence of events and the contents of section 18 of CCHD’s personnel policy manual, it seems like Christine Brooks could claim a wrongful discharge against CCHD. Termination of an employee in violation of an exception to the at-will employment doctrine is wrongful discharge. The traditional at-will employment doctrine provides that either the employer or the employee may terminate the relationship at any time for any or for no reason without liability. There are, however, limitations to this doctrine that limit the employer’s ability to terminate the employee without liability. 1 The specific limitations or exceptions are:

  • Contracts: The existence of a contract between the employee and the employer introduces limitations to the at-will employment doctrine. Examples of such contracts are: statements made regarding salary per period, statements of job assurance, substantive or procedural job security statements listed in the employee handbook.
  • Statute: An employer cannot violate the limitations imposed by state or federal statute. The employer cannot end the relationship by discriminating the employee on the basis of sex, color, national origin, race and religion.
  • Public policy: An employer may not terminate an employee for any reason that violates a state’s public policy. As public policy is a matter of common law, it varies from state to state. Most public policy exceptions fall into one or more of four broad categories as follows: (1) refusing to perform an illegal act, (2) reporting illegal activity, (3) exercising legal rights, and (4) performing public duties.2

Brooks could claim a breach of contract against CCHD. In order to substantiate her claim Brooks will need to provide evidence for the following:

  • A legally enforceable contract existed between her and CCHD, and
  • Some terms of the contract had been breached.

CCHD’s personnel policy manual stated the following related to terminations:

“Employment at the hospital is by mutual agreement and may be terminated by either the employee or the employer. All employee records will indicate the nature of termination which will be one of the following: (1) resignation, (2) quitting (3) layoff, (4) dismissal, (5) termination during probationary period, or (6) retirement.”3 This statement seems to convey at-will employment. In the same section, the manual states:

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“e. Dismissal - Employees may be dismissed for cause such as insubordination, serious misconduct, or for inability to perform the duties of their job satisfactorily. Department Heads and Supervisors may place an employee on suspension but all dismissal action must be reviewed by the Personnel Officer and approved by the Administrator before action will be taken. Dismissal will be classified as follows:

(1). Dismissal with Notice - Employees judged incapable of performing the duties of their job satisfactorily and have worked beyond the probationary period will receive two weeks notice or two weeks pay in lieu of notice, at ...

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