TEICHMILLER V. ROGERS MEMORIAL HOSPITAL, INC. 597 N.W.2d 773 (1999) CASE BRIEF

TEICHMILLER V. ROGERS MEMORIAL HOSPITAL, INC.

597 N.W.2d 773 (1999)

NATURE OF THE CASE: Teichmiller (P) appealed a decision granting summary judgment to Rogers (D) on P's claim based on wrongful discharge and false imprisonment.

FACTS: P a registered nurse, was an at-will employee of D. One of P's responsibilities was to perform patient intake and multidisciplinary assessments. Another of her responsibilities was to complete medical records or charts. P sued D alleging that she was directed to falsify medical records and that her refusal to do so resulted in her forced resignation and false imprisonment. P's false imprisonment claim arises from a confrontation between P and her superiors at a meeting to discuss her impending departure. P testified that she was asked to meet at the clinic with D. The purpose of the meeting was to discuss P's exit requirements, specifically the need to complete medical records before she departed. P sat in the chair nearest the door, which remained open during the meeting. She was handed the exit requirements and was told that she would be assisted in completing her charts. P refused to sign the form and stated that she had consulted an attorney. Ds became very excited and started shouting about P's contact with an attorney. When P stated that she wanted to make a copy of the document, Ds left their chairs. One party came to P's right side and blocked the doorway. The other came to P's left side. They screamed at P that she was stealing hospital property because she was going to take the exit requirements form to the copier in the conference room. Ds continued to stand on either side of P and attempted to grab the form from P's hands. P felt caged and could not move left or right because she was boxed in by Ds, her chair was behind her, and the office desk was in front of her. Ds held their hands approximately one-inch above P's arms while they were trying to grab the form. P felt that they were being aggressive and were dangerous. P was afraid to make a move. This standoff took three to four minutes and then on P's third attempt to move to the right, they stepped aside and P left for the copier. Ds 'chased' P to the copy room where they stood on either side of her as she unsuccessfully tried to use the copier, followed her to her office, and 'guarded' her from outside of the women's restroom where she fled after her first attempt to use the copier. P concedes that she was not touched or threatened with physical contact, although she felt threatened physically and verbally because Ds were in proximity to her and were excited. P never actually asked to leave the office. P repeatedly stated that she needed to make a copy of the document and because the copier was not located in the office, she believes she made it clear that she had to leave the room. The court granted summary judgment to Ds and P appealed.

ISSUE:

RULE OF LAW:

HOLDING AND DECISION:

LEGAL ANALYSIS:

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