Nayak v. St. Vincent Hosp. & Health Care Ctr. (Summary)

EMPLOYMENT DISCRIMINATION

Nayak v. St. Vincent Hosp. & Health Care Ctr., No. 1:12–cv–00817–RLY–DML (S.D. Ind. May 22, 2014)

The United States District Court for the Southern District of Indiana granted in part and denied in part a hospital’s motion for summary judgment regarding a former employee’s allegations of discrimination on the basis of disability, gender, and national origin.

The court held that the former employee, an OB/GYN resident, had not presented enough evidence to support claims of discrimination and retaliation on the basis of national origin.  The court concluded that the evidence presented in the case simply demonstrated the existence of “a possible cultural divide between American and Indian styles of communication and hospital norms” – not intentional discrimination.  The court dismissed her claim that she was terminated in retaliation for complaining about a hostile work environment because there was no evidence that the resident had complained to anyone with decision-making authority.

The court denied the hospital’s motion for summary judgment on the resident’s claims of gender and disability discrimination based, in part, on a document written by one of the supervising physicians which stated that the hospital terminated the resident’s contract because of “a medically complicated pregnancy and significant concerns regarding her academic progress.”  The court found that “this is direct evidence of discrimination” and that a reasonable jury could conclude that the plaintiff was terminated because of her medically complicated pregnancy in violation of both Title VII, which prohibits employment discrimination on the basis of sex, and the Americans with Disabilities Act.