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6th Circuit Affirms Summary Judgment in Nurse's Age Bias Case

The Sixth Circuit Court of Appeals affirmed a district court's summary judgment ruling in favor of Firelands Regional Medical Center in an age discrimination lawsuit filed by nurse practitioner Laura Obergefell. Obergefell claimed she was terminated due to her age rather than legitimate pandemic-related layoffs.

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Seal of the Sixth Circuit Court of Appeals

Case Information

Case No.:
25-3212

Key Takeaways

  • Sixth Circuit affirmed summary judgment for Firelands Regional Medical Center in age discrimination case
  • Laura Obergefell, 58, claimed age bias in her 2020 termination during COVID-19 pandemic layoffs
  • Court found insufficient evidence to support discrimination claims against legitimate business reasons

The Sixth Circuit Court of Appeals affirmed a lower court's summary judgment ruling against a nurse practitioner who claimed age discrimination in her termination during COVID-19 pandemic layoffs at an Ohio medical center.

Laura Obergefell, who worked as a full-time nurse practitioner at the Firelands Regional Medical Center Wound Care Center in Sandusky, Ohio, from 2008 until her termination in 2020, filed the lawsuit claiming her firing was motivated by age discrimination rather than legitimate business reasons. Obergefell was 58 years old at the time of her termination.

The case, filed as *Laura Obergefell v. Firelands Regional Medical Center*, arose from Obergefell's termination as part of a reduction in force during the COVID-19 pandemic. Firelands Regional Medical Center implemented the layoffs as healthcare facilities nationwide faced unprecedented financial pressures due to canceled elective procedures and increased operational costs during the public health emergency.

Obergefell's lawsuit included multiple claims against the medical center. She sued under both federal and state age discrimination laws, alleging that her age, not the reduction in force, was the hospital's true motive for her termination. The complaint also included state law claims for wrongful discharge, fraud and misrepresentation, and intentional infliction of emotional distress.

The case proceeded through the U.S. District Court for the Northern District of Ohio, where Firelands Regional Medical Center sought summary judgment on all claims. Summary judgment is a legal procedure that allows courts to resolve cases without a trial when there are no genuine disputes about material facts and one party is entitled to judgment as a matter of law.

The district court granted summary judgment in favor of the medical center on all of Obergefell's claims, finding that she had not presented sufficient evidence to support her allegations. This ruling effectively dismissed her case without allowing it to proceed to trial.

Obergefell appealed the district court's decision to the Sixth Circuit Court of Appeals, which has jurisdiction over federal appeals from Ohio, Michigan, Kentucky, and Tennessee. The three-judge panel that heard the case consisted of Circuit Judges Davis, Ritz, and Hermandorfer.

Circuit Judge Ritz authored the court's opinion, which was filed on Jan. 28, 2026. The appeals court examined whether Obergefell had presented sufficient evidence to create a genuine issue of material fact that would warrant a jury trial on any of her claims.

In affirming the district court's ruling, the Sixth Circuit found that Obergefell "did not offer sufficient evidence to create a jury question on any of her claims." This standard requires plaintiffs to present evidence that, if believed by a jury, could support a verdict in their favor. The court determined that Obergefell's evidence fell short of this threshold.

Age discrimination claims in employment typically require plaintiffs to establish that they were treated differently because of their age, and that age was a motivating factor in the employer's decision. Employers can defend against such claims by showing they had legitimate, non-discriminatory reasons for their actions, such as economic necessity or performance issues.

The COVID-19 pandemic created unique challenges for healthcare facilities, many of which faced severe financial strain due to postponed elective procedures and increased operational costs for personal protective equipment and safety protocols. Many hospitals nationwide implemented layoffs and furloughs during this period as they struggled with reduced revenue streams.

Firelands Regional Medical Center, like many healthcare facilities, implemented a reduction in force during the pandemic. The medical center argued that Obergefell's termination was part of these legitimate cost-cutting measures rather than age-based discrimination.

The appeals court's decision is designated as "not recommended for publication," which means it has limited precedential value and typically indicates the court viewed the case as applying settled law to specific facts rather than establishing new legal principles.

For Obergefell, the ruling represents the end of her federal court challenge unless she seeks review from the Supreme Court, which rarely accepts such cases. The decision leaves the summary judgment ruling in place, meaning the medical center prevailed on all claims without the case going to trial.

The case highlights the challenges employees face in proving age discrimination claims, particularly when employers can point to legitimate business reasons for their decisions. It also reflects the legal complexities that arose from pandemic-era employment decisions as courts balance employee protection rights with employers' responses to unprecedented economic pressures.

The ruling adds to the body of case law addressing employment disputes that emerged from the COVID-19 pandemic, as courts nationwide have grappled with similar cases involving layoffs, terminations, and workplace changes implemented during the public health emergency.

Topics

age discriminationwrongful terminationreduction in forceCOVID-19 pandemicemployment lawfederal civil rights

Original Source: courtlistener

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