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Rednour v. Wayne Twp.

United States District Court, S.D. Indiana, Indianapolis Division

September 24, 2014


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[Copyrighted Material Omitted]

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For KRISTINE R. REDNOUR, Plaintiff: Courtney E. Campbell, Kevin W. Betz, BETZ & BLEVINS, Indianapolis, IN; Sandra L. Blevins, BETZ & ASSOCIATES, Indianapolis, IN.

For WAYNE TOWNSHIP, WAYNE TOWNSHIP FIRE DEPARTMENT, Defendants: Christine L. Zook, Megan J. Schueler, FERGUSON & FERGUSON, Bloomington, IN.

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This cause is before the Court on Defendants' Motion for Summary Judgment [Docket No. 38], filed on February 21, 2014 pursuant to Federal Rule of Civil Procedure 56(a); Plaintiff's Motion for Leave to File Surreply [Docket No. 91], filed on July 21, 2014; and Defendants' Motion for Leave to File Sur-Surreply [Docket No. 99], filed on September 15, 2014. For the reasons set forth below, Plaintiff's Motion for Leave to File Surreply is GRANTED in part and DENIED in part, Defendants' Motion for Leave to File Sur-Surreply is GRANTED, and Defendants' Motion for Summary Judgment is DENIED.


Plaintiff Kristine Rednour was employed by Defendant Wayne Township Fire Department (WTFD) as a paramedic from 2009 to 2011. She began her employment with WTFD in February 2009 as a reserve paramedic; in June 2009, she became a full time civilian paramedic. Rednour Dep. 45.

The Wayne Township Fire Department is a municipal entity providing fire protection and emergency services for the residents of Wayne Township, Marion County, Indiana. WTFD operates five firehouses in Wayne Township; each shift at each firehouse is staffed by two paramedics or emergency medical technicians (EMTs). Scott Dep. 149. These two emergency service providers typically operate as a team, with one driving an ambulance and the other administering patient care en route to a hospital. At the time when the events giving rise to this suit took place, Gene Konzen was the Fire Chief for Wayne Township and the head of WTFD. Konzen Dep. 33. Richard Scott was the Deputy Chief of Administration, whose responsibilities included the hiring and firing of employees and the administration of WTFD's rules, regulations, and policies. Scott Dep. 82-83, 129. Justin Sparks was the Division Chief of Emergency Medical Services, responsible for the supervision of WTFD's EMTs and paramedics. Sparks Dep. 49. Rednour's immediate supervisor at the firehouse was Lieutenant Felicity Morgan. Morgan Dep. 18. WTFD's written job description for a paramedic includes the following " essential functions and abilities" :

o " [A]bility to exercise judgment in unique and ever-changing environments, make quick, appropriate and rational decisions, perfo[rm][1] complex tasks, remain calm, and bring order to stressful situations," Konzen Aff., Ex. 1 at ¶ 4.1.5;
o " Ability to assess the medical needs of and provide care to patients, to carry patients and equipment under a wide variety of difficult circumstances, drive an emergency vehicle under all conditions, and record and accurately relay information by telephone, radio, in writing, and in person," id. at ¶ 4.1.7;
o " Ability to follow complex verbal and written instructions and confo[rm] to established practices, protocols, and policies," id. at ¶ 4.1.8;
o " Good oral and written communications skills with the ability to read technical info[rm]ation and accurately assimilate and use such info[rm]ation," id. at ¶ 4.1.9;

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o " Monitor[] patient while in transport and continue[] treatment as indicated; provide feedback as authorized to other involved personnel regarding outcome of [ambulance] run," id. at ¶ 4.6; and
o " Ability to safely and effectively operate emergency and non-emergency vehicles under all conditions." Id. at ¶ 4.7.1.

The WTFD Standard Operating Guidelines also provide that paramedics must be " in the vehicle and responding within one (1) minute of dispatch," and should arrive on the scene within 10 minutes for all emergency calls meeting urgency criteria. Konzen Aff., Ex. 2.

Rednour has type 1 diabetes, which was diagnosed when she was 12 years old. Rednour Dep. 50. She treats her diabetes with an insulin pump, and she monitors her blood sugar some 6-10 times per day. Id. at 55. For type 1 diabetics, the regular administration of insulin doses prevents life-threatening high blood sugar levels, but can in turn lead to hypoglycemia--an abnormally low blood sugar level that can impair cognitive and bodily functioning when it reaches certain thresholds.[2] Endocrinologist Samuel Wentworth, M.D. has treated Rednour's diabetes for more than twenty years. Because of Rednour's concerns about the long-term effects of high blood sugar on her health, Wentworth explains that Rednour " tends to run her blood sugars as close to physiological as possible," which creates a " tendency to have low blood sugar." Wentworth Dep. 39. See also Rednour Dep. 63. Rednour testifies that she begins to experience some initial physical symptoms when her blood sugar drops below 70 mg/dL: " When I can't communicate or I start yawning . . . I check my sugar, and that's usually right below 70 . . . my yawning will start at 74 and below." Rednour Dep. 63. Rednour made ...

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