Martha Knotts v. Grafton City Hospital

Summary

The West Virginia Supreme Court of Appeals affirmed summary judgment for Grafton City Hospital in Martha Knotts’s age-discrimination action under the West Virginia Human Rights Act. The court held that Knotts failed to establish a prima facie case because her replacement and proposed comparators did not support an inference of age discrimination under existing West Virginia law. The court declined to address pretext because the prima facie case was not established.

Holdings

1. The circuit court's entry of summary judgment is reviewed de novo, and summary judgment is proper when the record shows no genuine issue of material fact and the moving party is entitled to judgment as a matter of law.
2. A plaintiff establishes a prima facie case of employment discrimination under the West Virginia Human Rights Act by proving that the plaintiff is a member of a protected class, the employer made an adverse employment decision, and but for the plaintiff's protected status the adverse decision would not have been made.
3. The court declined to overrule existing West Virginia law requiring the plaintiff to establish the applicable prima facie standard under Conaway and Young; evidence that a replacement was substantially younger but still over forty was insufficient on the record to establish Knotts's prima facie case.
4. Comparator evidence involving employees who were also over forty did not establish an inference of age discrimination because those employees were members of the same protected age class as Knotts.
5. The court did not reach the pretext issue because Knotts failed to establish a prima facie case of age discrimination.

Questions Presented

1. Whether evidence that Knotts was replaced by an employee substantially younger than her, but still over forty, established a prima facie case of age discrimination under the West Virginia Human Rights Act.
2. Whether evidence that Knotts was treated less favorably than substantially younger employees, who were also over forty, established a prima facie case of age discrimination.
3. Whether Knotts presented sufficient evidence that the hospital's legitimate, nondiscriminatory reason for termination was pretextual.

Disposition

affirmed