Craig v. Yale Univ. School of Med. (Summary)

EMPLOYMENT DISCRIMINATION

Craig v. Yale Univ. School of Med., No. 3:10cv1600 (JBA) (D. Conn. Mar. 4, 2013)

The United States District Court for the District of Connecticut granted a hospital’s motion for summary judgment against a former OB/GYN resident’s allegations of discrimination and hostile work environment.

In the case, the resident, who is an African-American male, entered the hospital’s OB/GYN residency program and, within a month of beginning the program, his substandard clinical performance had raised concerns with the program’s directors to the point that they intervened and met with the resident to discuss specific weaknesses in his clinical skills.  These weaknesses did not improve over time, and the resident’s reviews from the attending physicians and senior residents were uniformly critical and raised serious concerns about patient safety.  The resident was dismissed from the residency program after six months, but a grievance panel subsequently reinstated him for a probationary period.  The resident then failed the probationary period and was terminated from the residency program.  He filed suit, alleging race and gender discrimination and hostile work environment.

The court granted the hospital’s motion for summary judgment for the race and gender discrimination allegations.  For these claims, the resident sought to create a prima facie case for inferring discriminatory intent.  Although the court applied a lenient standard for the “qualification” element of the prima facie test – it only required the resident to show that he possessed the basic skills necessary for the job – the court nevertheless concluded that the resident failed to establish a prima facie case because the resident failed to present evidence that could permit a finder of fact to infer a discriminatory motive.  Furthermore, the court concluded that the hospital had established nondiscriminatory reasons for dismissing the resident that obviated the resident’s allegation of intentional discrimination.

The court granted the hospital’s motion for summary judgment for the hostile work environment claim because it concluded that the resident had failed to present sufficient evidence to support a conclusion that the pressure, inhospitality, and humiliation that the resident experienced at the hospital were the product of discriminatory intent.