Lawrence v. Mehlman (Summary)

DISCRIMINATION

Lawrence v. Mehlman, No. 09-4409-cv (2d Cir. Aug. 10, 2010)

The Court of Appeals for the Second Circuit affirmed a lower court’s decision which granted summary judgment in favor of hospital-defendants in a racial discrimination case brought by a plaintiff-physician.

The plaintiff was reprimanded for failure to meet the standard of care after he failed to see a patient who had suffered a miscarriage. However, after an investigation, the hospital concluded that the physician did meet the standard of care and the reprimand was withdrawn within six weeks. The appeals court held that the physician failed to establish a prima facie case or an inference of discrimination because the reprimand, withdrawn within six weeks, did not rise to the level of a materially adverse change in the terms and conditions of employment and did not, as a matter of law, constitute adverse employment action.