Hamdan v. Ind. Univ. Health N. (Summary)

RACIAL DISCRIMINATION

Hamdan v. Ind. Univ. Health N., No. 1:13-cv-195-WTL-MJD (S.D. Ind. Nov. 5, 2014)

fulltextThe U.S. District Court for the Southern District of Indiana granted in part a hospital’s motion for summary judgment against a discrimination lawsuit filed by a cardiologist. The cardiologist, a practicing Muslim of Palestinian descent, sued for race discrimination, intentional infliction of emotional distress, and defamation. In particular, he claimed that hospital employees had made derogatory and discriminatory remarks about him on numerous occasions and had filed false complaints that harmed his professional reputation.

Against the claim of race discrimination, the hospital emphasized that its bylaws did not create any sort of contractual relationship between itself and the cardiologist. The court was unpersuaded, determining that enough of a contractual relationship existed between the parties to fall within the scope of the federal antidiscrimination law. In addition, the court concluded that the cardiologist had presented sufficient evidence to go to trial on a so-called “cat’s paw theory” of liability, which applies to situations where a biased subordinate “dupes” an organization’s formal decision-makers into taking discriminatory employment actions. In this case, it determined that catheterization lab (“Cath Lab”) employees who were motivated by racial animus could have tricked the hospital into investigating the cardiologist. Therefore, it denied the hospital’s motion for summary judgment on the race discrimination claim.

In defense against the defamation claim, the hospital argued that it was entitled to immunity under federal and state law because the complaints provided information to a professional review committee. The court did not agree, instead concluding that the cardiologist had raised genuine issues of fact as to whether the Cath Lab employees made complaints in good faith. It did grant the hospital’s motion for summary judgment against a specific defamation claim filed against another physician.

The court denied the hospital’s motion for summary judgment on the intentional infliction of emotional distress (“IIED”) claim. It explained that its denial of summary judgment against the cardiologist’s other claims entailed that the IIED claim would survive as well. In addition, the court denied the cardiologist’s competing motion for summary judgment on the race discrimination claim, ruling that the matter would need to go to a jury trial for resolution.