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Mullins v. Virginia Lutheran Homes, Inc.
Citations: 479 S.E.2d 530; 253 Va. 116; 1997 Va. LEXIS 6Docket: Record 960961
Court: Supreme Court of Virginia; January 10, 1997; Virginia; State Supreme Court
Original Court Document: View Document
The case involves an appeal by Theresa A. Mullins against her former employer, Virginia Lutheran Homes, Inc., regarding her alleged unlawful discharge for filing a workers' compensation claim. Mullins, a certified nursing assistant, sustained an injury while aiding a resident and was subsequently instructed by her supervisor to complete her shift before seeking medical help. After being treated, she was advised by her orthopedist to limit her work activities, but her employer claimed no light-duty positions were available. Mullins stopped working at the end of October 1993, after which she received limited sick pay but no further wages. On December 2, 1993, the employer notified Mullins that her medical leave would expire soon and that her position could be filled if she did not return by that date. Following a meeting on December 6, where she was informed of her termination due to her inability to return to work, Mullins later sought to return but was told no positions were available. At trial, the court struck Mullins' evidence regarding her unlawful discharge claim, stating the jury's conclusions would require speculation on whether her discharge was solely due to her filing a claim under the Virginia Workers' Compensation Act (Code 65.2-308). Mullins appeals, asserting that the evidence was sufficient to warrant a jury's consideration of her claim. Mullins claims sufficient evidence supports that her employment was terminated due to her filing a workers' compensation claim. The employer counters that the evidence does not establish that her firing was solely related to this claim, arguing her termination was linked to her exhaustion of sick leave. The court disagrees with the employer, emphasizing that in evaluating a plaintiff's evidence, all reasonable inferences must favor the plaintiff and any reasonable doubt about evidence sufficiency should be resolved in her favor, citing prior cases. The court notes that employer motivation for termination is typically determined by circumstantial evidence. Referencing a similar case, the court illustrates that the determination of employer motivation lies outside the employee's knowledge, and the plaintiff's evidence raises a factual question regarding the employer's true motivation. Testimonies indicated Mullins was discharged shortly after her claim, with evidence suggesting her dismissal was related to her job-related injury. The employer’s stated reasons for the termination do not provide alternative explanations that would necessitate jury speculation. The trial court's decision to strike Mullins’ evidence was deemed erroneous, leading to a reversal of the judgment and a remand for a new trial. The employer's new argument on appeal regarding Mullins' entitlement to a jury trial on her claim is dismissed as it was not raised during the trial, and therefore, the court does not address its merits.