Last week, in Meeks v. Allen Memorial Hospital, a state court in Iowa approved a $2 million settlement in a race discrimination class action against an Iowa hospital. This case is yet another reminder that health care employers must consider both federal and state laws when assessing their employment practices.

The named plaintiff in the case, Robyn Meeks, is an African-American nurse who had previously worked for Allen Memorial Hospital until she resigned in 2003 after a failed mediation in a race discrimination case she filed with the Equal Employment Opportunity Commission (EEOC) against the hospital.

Then, in 2010, Meeks filed suit in state court under the Iowa Civil Rights Act, rather than Title VII of the Civil Rights Act of 1964, on behalf of African-American applicants and employees who she claimed were denied employment and promotions due to a pattern and practice of race discrimination. In support of her claim, Meeks alleged that she applied for a number of nursing jobs with Allen Hospital starting in 2008 and was rejected for each position. Meeks further alleged that she was asked during one interview whether she had considered applying for a position with another hospital. Meeks claimed that the applicants who were ultimately selected for the available positions were less-qualified white applicants.

The hospital denied any wrongdoing but nevertheless agreed to settle the class action for $2 million. As part of the settlement, Meeks was reinstated with back pay. Additionally, the hospital agreed to review some 14,000 job applications to determine if race was a factor in any of the employment decisions.

This case serves as yet another reminder that healthcare employers must consider both federal and state laws when assessing their employment practices.  A number of states place additional employment requirements on employers while creating additional protections for employees that are not available under Title VII or other federal laws.  Additionally, even where the state substantive law is essentially the same as its federal counterpart, state courts may have class action procedures that are more hospitable to class action plaintiffs, and potential damages may be greater, creating a further incentive for plaintiffs to pursue relief under state statutes.  Accordingly, it is critical for healthcare employers to consider both federal and state laws when developing employment policies and making employment decisions based on those policies.

Photo credit: Matthew S. Rambo