Adams v. Yale New Haven Hosp. — Mar. 2014 (Summary)
DISCRIMINATION
Adams v. Yale New Haven Hosp.
No. 12-4279-cv (2nd Cir. Mar. 12, 2014)
The United States Court of Appeals for the Second Circuit affirmed a lower court’s dismissal of a former physician associate’s claims of racial discrimination, sex discrimination, and retaliation. The plaintiff, an African-American male, worked as a physician associate in the hospital’s Surgery Department, but transferred to another department to avoid having to periodically be on call. Several weeks later, a new administrative position was created within the Surgery Department and offered to the remaining physician associate who negotiated an arrangement where she would not have to take call. The plaintiff then filed charges against the hospital, alleging that he was not offered the leadership position due to discrimination.
The court held that the plaintiff was not qualified for the position because he no longer worked in the Surgery Department. His discrimination claim therefore failed. In regard to claims of retaliation, the court affirmed that the plaintiff’s voluntary transfer did not constitute any adverse action on behalf of the hospital.