Thomila Nethery v. Quality Care Investors, L.P.

Summary

The Sixth Circuit affirmed summary judgment for the defendant nursing home in a Title VII retaliation claim, holding that the nursing home was not the plaintiff's joint employer because her actual employer retained control over her employment terms. The court also found that the nursing home did not significantly interfere with her access to employment opportunities under *Christopher v. Stouder Memorial Hospital*, as the employer had the sole power to remove her and offered a transfer. The case addresses the limits of joint employer liability and interference with employment opportunities under Title VII.

Holdings

1. Nethery did not provide sufficient evidence that Quality Care acted as her joint employer.
2. Quality Care did not significantly interfere because Reliant at all times held the sole power to remove Nethery and offer other employment opportunities.

Questions Presented

1. Whether Quality Care was Nethery's joint employer under Title VII.
2. Whether Quality Care interfered with Nethery's access to employment opportunities with Reliant under Christopher v. Stouder Memorial Hospital.

Disposition

affirmed