SAMANTHA GRAF v. MORRISTOWN-HAMBLEN HOSPITAL ASSOCIATION; SHIELD AND BUCKLER SECURITY, INC. - Articles

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Posted by: Azya Thornton on Sep 10, 2025

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ARGUED: Heather Moore Collins, HMC CIVIL RIGHTS LAW, PLLC, Nashville, Tennessee, for Appellant

Attorneys 2: ARGUED: Jay W. Mader, ARNETT, BAKER, DRAPER & HAGOOD, LLP, Knoxville, Tennessee, for Appellee Morristown-Hamblen Hospital Association.

Attorneys 3: ON BRIEF: Heather Moore Collins, HMC CIVIL RIGHTS LAW, PLLC, Nashville, Tennessee, for Appellant.

Attorneys 4: ON BRIEF: Jay W. Mader, Paul E. Wehmeier, ARNETT, BAKER, DRAPER & HAGOOD, LLP, Knoxville, Tennessee, for Appellee Morristown-Hamblen Hospital Association

Judge(s): MOORE, GRIFFIN, and NALBANDIAN, Circuit Judges

Court Appealed: United States District Court for the Eastern District of Tennessee at Greeneville

KAREN NELSON MOORE, Circuit Judge. While working as a Certified Nursing Assistant Technician at Morristown-Hamblen Hospital Association (“MHHA”), Samantha Graf lodged a complaint of sexual harassment with a representative of the hospital’s human-resources department. According to Graf, during a lunch break and on hospital grounds, one of the hospital’s security guards, Thomas Ogle, had raped her. After conducting a limited investigation into the complaint, the HR representative determined that the sexual interaction between Graf and Ogle had been consensual. Shortly thereafter, MHHA terminated Graf on the grounds that she had violated hospital policy by having intercourse while on the clock and in an unauthorized area. Graf filed suit against MHHA alleging violations of Title VII and the Tennessee Human Rights Act (“THRA”) and bringing various state tort claims. Two of those claims—Graf’s retaliation claim and her claim of negligent infliction of emotional distress—survived summary judgment. Prior to trial, MHHA moved for the admission of a variety of evidence of Graf’s sexual history pursuant to Federal Rule of Evidence 412(a), including evidence of Graf’s relationship with Ogle. The district court denied in part and granted in part the motion, allowing MHHA to introduce evidence of Graf’s communications with Ogle prior to and following the alleged rape. The case proceeded to trial, and a jury returned a verdict in favor of MHHA on all counts. On appeal, Graf challenges the judgment against her, arguing that the district court erred as a matter of law in interpreting Title VII to require that she prove that she did not consent to the alleged rape. And she argues that the district court abused its discretion in admitting a variety of evidence of her sexual history and predisposition, in violation of Federal Rule of Evidence 412. But because the district court accurately interpreted the requirements of Graf’s Title VII retaliation claim, and because it did not abuse its discretion in allowing the admission of limited evidence of her sexual history, we AFFIRM.

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