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Bradford v. Jackson Parish Police Jury

United States District Court, W.D. Louisiana, Monroe Division

October 23, 2019

CORA BRADFORD
v.
JACKSON PARISH POLICE JURY, ET AL.

          KAREN L. HAYES Judge

          RULING

          TERRY A. DOUGHTY UNITED STATES DISTRICT JUDGE

         Pending before the Court is a Motion for Partial Summary Judgment on Plaintiff's Wage Discrimination Claims [Doc. No. 47] filed by Defendant Jackson Parish Hospital Service District No. 1 d/b/a Jackson Parish Hospital (“the Hospital”). The Hospital moves for summary judgment dismissing Plaintiff Cora Bradford's (“Bradford”) wage discrimination claims.

         On September 30, 2019, Bradford filed a Memorandum in Opposition to the Motion for Partial Summary Judgment [Doc. No. 49].

         On October 4, 2019, the Hospital filed a Reply Memorandum in support of its Motion for Partial Summary Judgment [Doc. No. 50].

         For the following reasons, the Hospital's Motion for Partial Summary Judgment is GRANTED, and Bradford's wage discrimination claims are DISMISSED WITH PREJUDICE.

         I. FACTS

         Bradford, a Black female, was formerly employed by the Hospital. She was last employed as Chief Financial Officer (“CFO”).

         Bradford's predecessor as CFO was a white male, Eric Cripps (“Cripps”). Cripps was originally hired as an accountant in September 2008 and promoted to business team leader in January 2011. He resigned on September 21, 2012, but returned to work at the hospital on February 1, 2013. On May 4, 2015, Cripps was promoted to CFO, with a salary of $90, 000.00. Cripps continued to serve as CFO until December 14, 2015, when he began serving as both the CFO and the Chief Operating Officer (“COO”). At that time, his salary was increased to $100, 000.00. Then-Chief Executive Officer (“CEO”) Bobby Jordan approved the raise and provided a detailed explanation of the duties Cripps assumed as COO. Cripps resigned on September 22, 2016.

         Bradford was first employed by the Hospital on December 1, 2015, as an accountant. After Cripps' resignation, on October 14, 2016, Bradford was promoted to CFO. Her salary was then increased from $85, 000, to $90, 000.00. She did not take on the role of COO, only that of CFO.

         The Hospital terminated Bradford on September 26, 2017, for alleged poor job performance.

         On or about October 28, 2017, Bradford filed a charge with the Equal Employment Opportunity Commission (“EEOC”), alleging that the Hospital discriminated against her on the basis of race and color. [Doc. No. 34, ¶ 25]. The EEOC issued Bradford a Dismissal and Notice of Rights on August 1, 2018. [Doc. No. 34, ¶ 26].

         On October 23, 2018, Bradford filed her original Complaint in this Court against the Hospital and Inquiseek, LLC (“Inquiseek”), a consulting firm hired by the Hospital to evaluate its accounting functions. In her original Complaint, Bradford alleging wrongful termination, disparate treatment, and wage disparity in violation of Title VII of the Civil Rights Act of 1964, 42 USC § 2000e, et seq. (“Title VII”); 42 U.S.C. §§ 1981 &amp. 1983; the Equal Pay Act of 1963 (“the Equal Pay Act”), 29 U.S.C. §206, an amendment to the Fair Labor Standards Act (“FLSA”), 29 USC § 201; and the Louisiana Employment Discrimination Law (“LEDL”), La. Rev. Stat. § 23:332. See [Doc. No. 1, ¶¶ 17-19]. Additionally, she asserted state tort claims against Inquiseek based on alleged verbal abuse and threats by its agent, Jeff Harper. She sought lost wages and benefits; liquidated, exemplary, and punitive damages; attorneys' fees, interests, and costs; and an injunction enjoining Defendants from engaging in the alleged discrimination and requiring them to take affirmative actions to redress their discriminatory practices.

         On November 12, 2018, the Jackson Parish Police Jury and the Hospital filed an Answer to the Complaint in which they clarified that they had been improperly named in the Complaint as a single entity (the “Jackson Parish Police Jury d/b/a Jackson Parish Hospital”), effectively substituting themselves as Defendants. [Doc. No. 5]. On November 13, 2018, Inquiseek filed its answer. [Doc. No. 6].

         On January 15, 2019, all three Defendants filed motions to dismiss. The Police Jury moved to dismiss the claims against it because it was neither Bradford's employer, nor took any of the challenged actions. [Doc. No. 11]. Bradford filed a statement of no opposition to this motion. [Doc. Nos. 22 & 23]. The Court granted the motion, and all claims against the Police Jury were dismissed. [Doc. No. 24].

         Inquiseek also filed a motion to dismiss Bradford's claims for tortious interference with contract, intentional infliction of emotional distress, and for punitive damages. [Doc. No. 14]. Bradford filed an opposition [Doc. No. 25], and Inquseek filed its reply [Doc. No. 30].

         The Hospital filed a motion to dismiss seeking dismissal of Bradford's claims against it under Sections 1981 and 1983, the Equal Pay Act, and for punitive damages. [Doc. Nos. ...


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