Jamaleddin v. Oakland Physicians Med. Ctr. (Summary)

DISCRIMINATION/ BREACH OF CONTRACT

Jamaleddin v. Oakland Physicians Med. Ctr., No. 13–cv–12735 (E.D. Mich. Jan. 12, 2015)

The United States District Court for the Eastern District of Michigan granted a hospital’s motion for summary judgment against a resident’s claim of retaliatory harassment, while denying its motion for summary judgment against the resident’s claims of national origin discrimination and breach of contract.

The resident, who was of Arabic descent, had executed a “residency agreement” with the hospital and accepted appointment as a first year resident in family medicine. The resident received several warnings about his professionalism and his communication skills. In his lawsuit, the resident argued that these warnings were rooted in discriminatory motives. He alleged that one of his direct supervisors had told him to “give up [his] Arabic mentality” and had made jokes about whether the resident was using “Arabic time.”

The resident decided to tell another supervisor that he believed he was being discriminated against because of his Arabic descent. That same evening, the resident asked another physician to complete a patient history for him so that he did not have to stay overtime. The hospital discovered this and then fired the resident a week later. According to the resident, the hospital then forced him to sign a resignation form instead of appealing the decision, threatening him that he would “end up nowhere” unless he complied.

The court ruled in favor of the hospital on the retaliation claim, finding that although the resident alleged that he was fired just a week after complaining about discrimination to his supervisor, there was insufficient proof of a causal connection between the two events. However, the court ruled against the hospital on the discrimination claim, noting that even though the hospital had warned him about a lack of professionalism and deficient interpersonal skills, the resident had immediately corrected many of the flaws after he learned about them. In addition, the resident had shown that several of his supervisors gave him positive performance evaluations in the past, undercutting their argument that he was a problem employee. The court also ruled against the hospital on the breach of contract claim, because the residency agreement itself included a clause preventing discrimination on the basis of national origin.