Hospital right in firing worker, Justices rule
CHARLESTON – Williamson Memorial Hospital managers properly terminated a brand new employee whose special treatment upset other workers, the West Virginia Supreme Court of Appeals has ruled on Dec. 12. The Justices agreed that the hospital employed Crystal Hatfield "at will," finding that her contract did not specify the duration of her employment. Their Dec. 12 unsigned opinion affirmed Mingo Circuit Judge Michael Thornsbury, who granted summary judgment to Williamson Memorial. Hatfield started working there in 2005 as benefits and special projects coordinator at $14 an hour, for an annual salary of $29,120. Her situation disturbed other workers because human resources director Rob Channell had made the job sound unattractive. Despite the impressive title, the job notice called for filing, shredding and typing. When workers had asked what the position would pay, Channell told them $7 to $9. They already made that much or more, so they hadn't applied. As suspicions swirled around the new person, someone reported that she was the fiance of the son of plant operations director Gregg Moore. Someone reported that she didn't have a two year degree. Channell had deterred some inquiries by telling workers the job required a two-year degree. Mutiny loomed, but Channell and Moore didn't deal with it. Neither did chief executive officer Robert Mahaffey, who had interviewed Hatfield. Jacqueline Adkins and Cassie Ball dealt with it. The Supreme Court opinion does not give their titles, identifying them as "individuals in charge of hospital operations." They investigated, according to the Justices, "and determined that terminating the appellant was the only way to appease the disgruntled hospital employees." On the fourth day, at the direction of Adkins and Ball, Channell terminated Hatfield. Hatfield sued the hospital's parent, Health Management Associates of West Virginia, and she sued Adkins and Ball. She alleged breach of contract, breach of duty of good faith and fair dealing, detrimental reliance, tortious interference, and intentional infliction of emotional distress. Five months after her termination, she regained her former job in Charleston at $12. She persisted in her claims against the hospital, Adkins and Ball, but Thornsbury rejected the first three claims in 2006 and the other two in 2007. He decided correctly on all five, the Justices agreed. On the breach of contract claim they quoted a 1955 decision that, "When a contract of employment is of indefinite duration it may be terminated at any time by either party to the contract." On the other breach claim they quoted a 1995 decision that they do not recognize an implied covenant of good faith and fair dealing in the context of at-will employment. On detrimental reliance, they found nothing to suggest that the hospital promised permanent employment. On tortious interference, they rejected Hatfield's argument that Adkins and Ball acted outside their job duties. "Our law is clear that, in order for a party to be held liable for intentional interference with a contractual relationship, the party must be someone outside of the contractual relationship," they wrote. Finally, they held that intentional infliction of distress must involve outrageous conduct. "The record is clear that the appellees did nothing to ridicule, harass, or verbally abuse the appellant, nor make any derogatory or inappropriate statements with respect to either her employment or her termination," they wrote. Debra Nelson and James Spenia, of Mundy and Nelson in Huntington, represented the hospital. Jeffrey Mehalic of Charleston represented Hatfield.