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Michigan Supreme Court Reverses and Remands Civil Rights Claims Against Senior Living Facility

The Michigan Supreme Court reversed a lower court's dismissal and remanded a workplace discrimination case involving a certified nursing assistant who alleged race-based harassment, gender harassment, and retaliation against American House Roseville I, LLC under the Elliott-Larsen Civil Rights Act.

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2 min readcourtlistener
Seal of the Michigan Supreme Court

Case Information

Case No.:
163989

Key Takeaways

  • Michigan Supreme Court reversed dismissal and remanded employment discrimination case against senior living facility under Elliott-Larsen Civil Rights Act
  • Certified nursing assistant alleged retaliation after reporting inappropriate conduct to HR and state authorities
  • Case involved 180-day contractual limitations period in employee handbook for bringing employment claims
  • Plaintiff claimed race-based harassment, gender harassment, hostile work environment, and wrongful discharge
  • Case returns to trial court for further proceedings following Supreme Court's reversal

The Michigan Supreme Court issued a reversal and remand order in *Timika Rayford v. American House Roseville I, LLC*, allowing claims of workplace discrimination and retaliation against a senior living facility operator to proceed. The case, decided July 31, 2024, after oral arguments in April, centers on allegations brought under the Elliott-Larsen Civil Rights Act (ELCRA) and related employment law claims.

Timika Rayford, a certified nursing assistant, filed suit in Macomb Circuit Court against American House Roseville I, LLC, alleging multiple violations of workplace civil rights protections. Her complaint included claims for race-based harassment, sex- or gender-based harassment, retaliation, and hostile work environment under Michigan's Elliott-Larsen Civil Rights Act, which prohibits discrimination in employment based on protected characteristics.

The case began when Rayford was hired by American House in February 2017 to work as a certified nursing assistant at the senior living facility. Approximately one week after beginning her employment, Rayford signed an "Employee Handbook Acknowledgment" containing a 180-day contractual limitations period for bringing employment-related claims.

The Michigan Supreme Court's reversal means the case will return to the trial court for further proceedings, where Rayford's claims can be adjudicated on their merits. The remand allows the lower court to reconsider the case in light of the Supreme Court's interpretation of applicable law. This development may influence how similar contractual limitations periods in employee handbooks are evaluated in future Michigan employment discrimination cases, though the ultimate impact will depend on how lower courts apply the Supreme Court's guidance in subsequent litigation.

Topics

race-based harassmentsex-based harassmentretaliationhostile work environmentwrongful dischargemalicious prosecutionabuse of processcontract unconscionabilitylimitations period

Original Source: courtlistener

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