Constructive Termination And Joint Employer Claims Were Properly Dismissed

Carla St. Myers worked as a nurse practitioner at a rural clinic that was part of a medical center owned and operated by Dignity Health. During her three years of employment, St. Myers submitted over 50 complaints about working conditions at the facility and also was the subject of several investigations based upon anonymous complaints. Although the investigations concluded that the complaints against St. Myers were unsubstantiated, she found another job and resigned but then alleged in a lawsuit that her resignation was a constructive termination of her employment due to "intolerable working conditions." St. Myers sued both Dignity Health and Optum360 Services (which provided revenue cycle services to Dignity Health). Dignity Health successfully moved for summary judgment in response to St. Myers's claims on the ground that St. Myers could not establish an adverse employment action because she was never subject to a disciplinary write-up, suspended, demoted or