Jones v. Temple Univ. (Summary)

DISCRIMINATION – RACE AND GENDER

Jones v. Temple Univ.
No. 12-5349 (E.D. Pa. July 10, 2014)

The United States District Court for the Eastern District of Pennsylvania granted a hospital’s motion to dismiss a radiologist’s race and gender discrimination claims, finding that the hospital’s actions were based on legitimate, nondiscriminatory reasons and that the radiologist had failed to show that she was treated less favorably than similarly situated white male radiologists. Plaintiff, a female African-American radiologist, worked at a university-affiliated hospital as the only part-time radiologist along with several other full-time radiologists. Throughout her employment at the hospital, the radiologist stated her preference to work part-time. The radiologist claimed the hospital discriminated against her on two occasions. First, when the hospital hired a new Chairman of Radiology, ultimately a white male, it did not consider her for the position; and, second, when the hospital terminated only her position for budgetary reasons.

The court held that the hospital’s actions were based on legitimate, business reasons that could give rise to any inference of discriminatory intent. The court stated that the hospital would not have reasonably known that the radiologist was interested in the chairman position because it was a full-time administrative position, and the radiologist had repeatedly stated her preference for part-time positions and that, in addition, the radiologist the hospital sought for the position had many more years of administrative experience. Additionally, the court stated that the hospital eliminated the radiologist’s position for legitimate budgetary reasons and her contract’s clause requiring 90-days’ notice before termination made terminating her contract far more appealing than terminating the contract of one of the full-time radiologists, whose contracts required a full year’s notice. Furthermore, the court agreed with the hospital that the radiologist was unable to show that she was treated less favorably than another similarly-situated radiologist because she was the only radiologist who worked part-time and, therefore, there was no other similarly-situated radiologist for comparison.