Sexual discrimination/harassment under the Michigan Civil Rights Act (CRA); MCL 37.2202(1)(a); Hostile-environment & quid pro quo sexual harassment; MCL 37.2103(ii) & (iii); Radtke v Everett; Hamed v Wayne Cnty; Function of a pleading; Dalley v Dykema Gossett; Admission of hearsay evidence under MRE 803(24); Invasion of privacy; Doe v Henry Ford Health Sys; Nyman v Thomas Reuters Holdings, Inc; Defamation; Ghanam v Does

The court held that the trial court did not err by granting defendant-former employer summary disposition of plaintiff-former employee’s claims for sexual discrimination, invasion of privacy, and defamation. Following her termination, she filed a “cursory” pro se complaint. Without holding oral argument, the trial court granted summary disposition for defendant, finding plaintiff’s complaint was “facially deficient, consisting of ‘broad statements and generalizations of mistreatment that are not expanded upon.’” It also found that in any event she “failed to present evidence to establish a prima facie case of sexual discrimination under hostile work environment or quid pro quo harassment, invasion of privacy, or defamation.” The court rejected her argument that the trial court erred by granting defendant’s motion for summary disposition because she stated plausible causes of action and presented sufficient evidence to establish her claims. It found that although the allegations in her complaint “were sufficient to put defendant on notice of a claim for hostile work environment on the basis of sexual harassment,” she did not offer “admissible evidence to establish a prima facie case” of such claim. Further, “even viewing the facts in the light most favorable to plaintiff, the complaint did not contain sufficient allegations to establish a cause of action for quid pro quo harassment.” And the trial court did not err by determining that her “evidence was not admissible and did not support her claims.” The court also found that she could not maintain claims for invasion of privacy or defamation. She “did not allege (1) what statements were disclosed, (2) that the statements were disclosed to a substantially large group of people, and therefore, the private information would become public knowledge, or (3) that the statements were highly offensive to a reasonable person.” The allegations “were too vague and facially deficient to put defendant on notice of the basis of plaintiffs claim of invasion of privacy.” Even if she had sufficiently pled “a cause of action for invasion of privacy under a theory of public disclosure of private facts,” the trial court properly granted summary disposition for defendant. Her complaint was also deficient to state a claim for defamation. She could not meet the first element, and despite asserting that the statements at issue “tarnished her reputation in her work community, caused her to suffer mental anguish, and caused her to experience hardship at her new place of employment,” she failed to present “evidence that she was harmed by the statements.” Affirmed.