Court addresses quid pro quo harassment; doesn't find any

The Plaintiff in Rouhani v. Bronson Battle Creek Hospital filed a lawsuit arguing that she was a victim of quid pro quo sexual harassment.  A female doctor with staff privileges at the hospital, Dr. Rouhani argued that after she complained to his supervisor about a hospital employee's inappropriate behavior, the hospital retaliated by mismanaging her patients and reducing her patient referrals.  The hospital did not actually track referral numbers, however, and the doctor was unable to verify precisely when and to what extent her referral numbers had changed.  As a result, the Court upheld the summary disposition of her claim.