STATE OF WISCONSIN
LABOR AND INDUSTRY REVIEW COMMISSION
P O BOX 8126, MADISON, WI 53708-8126
http://dwd.wisconsin.gov/lirc/

MIKHAIL L VASERMAN, Complainant

LAKESHORE MEDICAL CLINIC LIMITED, Respondent

FAIR EMPLOYMENT DECISION
ERD Case No. CR201004003, EEOC Case No. 26G201100205C


An administrative law judge for the Equal Rights Division of the Department of Workforce Development issued a decision in this matter. A timely petition for review was filed.

The commission has considered the petition and the positions of the parties, and it has reviewed the evidence submitted to the administrative law judge. Based on its review, the commission makes the following:

FINDINGS OF FACT

1. The complainant in this matter, Mikhail L. Vaserman (hereinafter "complainant"), is an individual whose national origin is Russian and whose creed is Jewish.

2. The respondent, Lakeshore Medical Clinic (hereinafter "respondent") is a business operating medical clinics in Wisconsin.

3. On October 5, 2009, the complainant was hired by the respondent to work as a specialty medical assistant. The complainant was to be assigned to work with three specific doctors.

4. At the time the respondent hired the complainant it was aware of his national origin and creed.

5. When the complainant reported for work on October 12, 2009, he learned that he had been reassigned to a float position and would not be working with specific doctors. The complainant asked Laurie Bornhoffer, the individual who hired him and who was responsible for making the work assignments, why this change occurred. Ms. Bornhoffer did not provide the complainant with any explanation.

6. Medical assistants who were not in the protected class and who were hired after the complainant did not have as much education or experience as he had, but were assigned to specific doctors and not required to work as floaters. They received job-specific training, while the complainant did not.

7. All medical assistants were assigned shifts cleaning the lunch room according to a schedule posted by the respondent. On one occasion a medical assistant directed the complainant to clean the lunch room even though it was her turn to do so. She told the complainant that he had to do it because he was from Russia and spoke with an accent and suggested she should send him to clean the restrooms also. On another occasion a different medical assistant was scheduled to clean the lunch room, but told the complainant it was his job because he was newest. Other workers laughed at the complainant and said he cleaned very well, and that maybe he could do it the next day. The complainant went to Ms. Bornhoffer and to human resources about these incidents, but no action was taken.

8. On January 2, 2010, the complainant filled out a "90 day New Employee Survey" and returned it to Adam Ably, the human resources generalist. In his survey responses the complainant stated that he was concerned about some team members' unprofessional and inappropriate behavior, which he characterized as involving a variety of objectionable conduct, including discrimination and sexual harassment. The complainant asked that the respondent protect him from discrimination and sexual harassment and that it "create and maintain a healthy and equal work environment that make me feel comfortable at work." The respondent never contacted the complainant to discuss his survey responses.

9. A doctor named Dr. Lubens told the complainant two times that he was a "crazy man." This took place on or about January 26, 2010.

10. On March 4, 2010, the complainant was assigned to work with Dr. Baman. The complainant roomed a patient and later heard the patient asking Dr. Baman who the complainant was, because he had never seen the complainant before. Dr. Baman responded that the complainant was a troublemaker from Russia. He later repeated the comment. The complainant requested to not be scheduled with Dr. Baman again because of the incident.

11. On March 11, 2010, Mr. Ably met with the complainant to give him a "Documented Discussion" for conduct involving sexual harassment. The respondent had not conducted an investigation or talked to the complainant before preparing the Documented Discussion paperwork, and the complainant disputed its contents. When the complainant protested, Mr. Ably laughed and stated that this was only a discussion and not a disciplinary action. During the meeting the complainant also told Mr. Ably that he had been discriminated against by Dr. Baman and harassed by other medical assistants.

12. On April 9, 2010, the complainant was again asked to work with Dr. Baman, but refused to do so. The complainant met with Ms. Bornhoffer and told her that he wanted actions taken against Dr. Baman because of the March 10 incident. Ms. Bornhoffer asked the complainant if he knew the name of the patient involved. The complainant stated he did not know, but would find out because he remembered the date and time of the appointment.

13. The respondent did not take any action against Dr. Baman. However, it later issued a "Documented Discussion" to the complainant in conjunction with the incident for what it maintained was a potential HIPAA violation.

14. On or about April 11, 2010, the complainant submitted a request to take time off for the observance of Jewish holidays, but his request was not approved.

15. During the course of his employment other medical assistants asked the complainant for assistance in translating from English to Russian or Ukrainian, which was not part of his job description, then refused to help him when he needed it.

16. On or about May 3, 2010, the complainant notified the respondent that he planned to resign.

17. On May 10, 2010, after the complainant had already tendered his resignation, he filled out paperwork requesting discretionary leave from June 1 until July 16, 2010.

18. On May 17, 2010, the complainant's last day of work, Mr. Ably and Marie Tratnik, the assistant clinic manager, met with the complainant to give him the "Documented Discussion" about the alleged HIPAA violation referred to in paragraph 13. The complainant asked Mr. Ably why he was not receiving an exit interview but did not receive any response.

Based on the FINDINGS OF FACT made above, the commission makes the following:

CONCLUSIONS OF LAW

1. There is probable cause to believe the respondent discriminated against the complainant based upon his national origin and creed, and because he opposed a practice of discrimination, in violation of the Wisconsin Fair Employment Act.

2. Based on the FINDINGS OF FACT and CONCLUSIONS OF LAW made above, the commission issues the following:


ORDER

The decision of the administrative law judge is reversed. The matter is remanded to the Equal Rights Division for further proceedings.

Dated and mailed February 28, 2014
vasermi_rrr . doc : 164 :  642 649

BY THE COMMISSION:

/s/ Laurie R. McCallum, Chairperson

/s/ C. William Jordahl, Commissioner

/s/ David B. Falstad, Commissioner

MEMORANDUM OPINION

This case is before the commission on probable cause.  The complainant's burden of proof in a probable cause proceeding is low. Wallace v. Certifying Service Express, ERD Case No. 200203258 (LIRC Dec. 13, 2004); Buska v. Central Bldg. Maintenance, ERD Case No. 9200725 (LIRC Sept. 28, 1995). While the commission has generally held that a complainant is required to do more than establish a prima facie case in order to sustain his or her burden of establishing probable cause to believe that unlawful discrimination has occurred, absent the respondent's presentation of evidence of a legitimate, nondiscriminatory reason for its actions, that is not the case. A finding of probable cause results where the respondent has offered no evidence at the hearing to rebut the complainant's prima facie case. Nevels-Ealy v. County of Milwaukee, ERD Case No. 200503213 (LIRC March 14, 2008), citing Gunderson v. Bonded Spirits Corp., ERD Case No. 8351917 (LIRC July 17, 1986).

In this case, the respondent appeared at the hearing without counsel, and then chose to introduce no evidence on its own behalf. Consequently, the complainant's evidence went unrebutted. While the complainant's evidence may be somewhat minimal, and while not all of his allegations support a finding of probable cause, the commission believes that the complainant has generally satisfied his burden of establishing a prima facie case of discriminatory terms and conditions of employment based upon his national origin and/or religion and based upon his protected conduct, such that, in the absence of any evidence by the respondent, a finding of probable cause is warranted.

The complainant testified that he was hired for a specialty medical assistant job assigned to specific doctors, but was later made to work as a floater. The respondent would not give him a reason why this occurred, even when he asked. The complainant contended that non-Russian, and presumably non-Jewish, employees with less educational background and practical experience were hired after the complainant but were not required to work as floaters. Although the administrative law judge found that the complainant's creed and national ancestry played no role in the respondent's decision to change his work assignment, no evidence was presented to support that finding -- the record offers no clue as to why the assignment was changed.

Next, the complainant testified that employees laughed at his Russian accent, made jokes at his expense, and that one co-worker made him clean the lunch room even though it was her turn, stating it was because he was Russian. The complainant complained about this, but nothing was done. (1)   The complainant also filled out a 90-day New Employee Survey in which he indicated that discrimination was occurring in the workplace, but the respondent did not respond to his complaints. Instead, the complainant was later given a "Documented Discussion" for conduct involving sexual harassment, which he believed was a fabricated charge in retaliation for his prior complaints. While the administrative law judge found that the Documented Discussion was "not affected in any way" by the complainant's complaints of harassment and discrimination, there is no support for this conclusion in the record. The complainant effectively denied engaging in sexual harassment, and the respondent introduced no evidence allowing a conclusion as to its motivations in issuing the Documented Discussion.

The complainant also testified that a doctor described him to a patient as a "Russian troublemaker," and that, although he complained, no action was taken against the doctor. Instead, the complainant was written up for a potential HIPAA violation related to the manner in which he obtained information about what patient the doctor was talking to when the statement was made. Although the administrative law judge indicated that he did not find it believable that Dr. Baman made the statement in question, given that the complainant was standing outside of the examining room and overheard it through a closed door, the complainant's testimony was simply that he heard Dr. Baman make the statement to the patient -- he did not state that he was outside of the room when the comment was made. The complainant's unrebutted evidence supports a conclusion that one of the respondent's employees made comments about the complainant's national origin which he perceived as offensive and that the respondent was unresponsive to the complainant's complaints.

The evidence summarized above is sufficient to support a finding of probable cause to believe that the complainant was discriminated against in the terms and conditions of his employment based upon his national origin, creed, and in retaliation for having complained to the respondent about discrimination. The complainant is therefore entitled to a hearing on the merits of his complaint. The parties should be advised that the remand hearing is an entirely new hearing which does not incorporate the record from the probable cause hearing. Evidence may be presented with respect to all of the allegations that were raised at the probable cause hearing, even if the commission has not specifically discussed them in its decision, including with regard to the denial of time off for Jewish holidays.  (2)



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Footnotes:

(1)( Back ) The administrative law judge found that none of the complainant's supervisors ever directed him to clean the lunch room and concluded that the complainant's national origin and creed played no role in how often his managers assigned him to clean the lunch room. However, the evidence did establish that the complainant was directed by management to clean the lunch room. Further, the complainant's allegation was not that management assigned him lunch room duty more often because of his creed or national origin, but that co-workers made him perform lunch room duties on days they were assigned to do so and that this was part of a pattern of harassment based upon his national origin about which he complained, without results.

(2)( Back ) At the probable cause hearing the administrative law judge refused to allow the complainant to submit any evidence on this point, stating that requests for time off for religious reasons must be separately pleaded as an accommodation issue and that, because the complainant did not specifically allege the refusal of a religious accommodation, the evidence on that point was excluded. The commission disagrees. In the first place, it is not clear from the record that the complainant was alleging the denial of an accommodation. His allegation that he was denied days off work could be considered part of a straightforward discriminatory terms and conditions complaint. Moreover, even if the matter is best analyzed as a request for a religious accommodation, the complainant would not be required to plead the matter separately. The pleading requirements of the Fair Employment Act are meant to be very liberal. Moeller v. County of Jackson, ERD Case No. CR200003908 (LIRC Jan. 27, 2003). An employer's failure to make an accommodation for an employee's religious observance can be considered raised by a complaint which charges the employer with discrimination with regard to the terms and conditions of his employment based upon religion, even where the complaint did not specifically allege such a failure. See, Teggatz v. LIRC (DHSS), No. C159-497 (Wis. Cir. Ct. Dane Cty., Oct. 3, 1977)(applying the same rule to a disability accommodation case).

 


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