Mehta v. HCA Health Services of Fla., Inc. (Summary)

EXCLUSIVE CONTRACT/EMPLOYMENT DISCRIMINATION

Mehta v. HCA Health Services of Fla., Inc., No. 8:06-CV-1284-T-24-MSS (M.D. Fla. Aug. 20, 2007)

The federal District Court for the Middle District of Florida granted summary judgment to a hospital in an employment discrimination suit brought against it by a radiologist. The claim arose out of the hospital’s decision not to renew its exclusive contract with a radiology services provider through whom the radiologist worked. The radiologist alleged that the hospital’s decision was based on the racist demands of one of its physicians.

The court indicated that there must either be direct or circumstantial evidence of discrimination for a claim of employment discrimination to survive. Because the physician who made the racist demands did not have any decision-making authority with regard to the renewal of the contract, the court concluded that there was no direct evidence of discrimination. The court also determined that there was no circumstantial evidence of discrimination. This determination was based on the lack of evidence showing that the hospital’s decision not to renew the contract was tainted by the physician’s discriminatory intent. In actuality, the undisputed evidence displayed that the hospital decided not to renew the contract after a thorough and independent assessment of the radiology service’s ability to provide services according to the hospital’s terms.