Mehta v. HCA Health Services of Florida (Summary)

EMPLOYEE DISCRIMINATION

Mehta v. HCA Health Services of Florida, No. 8:05-CV-27-T24-TGW (M.D. Fla. Oct. 31, 2006)

The United States District Court for the Middle District of Florida granted a hospital’s motion for summary judgment in a suit brought by a physician that alleged discrimination. The physician sued the hospital, claiming discrimination, after it did not renew its exclusive contract with the professional partnership of radiologists of which he was a partner. The district court found that to bring a Title VII suit under the federal Civil Rights Act, the physician had to be an employee of the partnership whose contract was not renewed by the hospital. As a partner, and not an employee, the physician failed to satisfy this requirement. The physician also failed on his claim under §1981, which alleged his privileges were terminated because of discrimination, as the “automatic expiration” provision concerning the physician’s medical staff appointment that was a part of the hospital’s contract with the partnership was not prohibited by the statute. Since the doctor failed to raise a genuine issue of material fact regarding his claims of discrimination, summary judgment was granted for the hospital.