Maduka v. Sunrise Hosp.

EMPLOYMENT DISCRIMINATION

Maduka v. Sunrise Hosp., No. 03-15332 (9th Cir. July 15, 2004)

A
physician appealed a district court’s judgment dismissing his complaint with
prejudice. The physician was involved in two incidents that prompted the revocation
of his staff privileges. He subsequently filed a federal civil rights action
against the hospital and several related entities, alleging discrimination
(that the hospital’s actions were motivated by his race). The hospital moved
to dismiss the complaint based on a failure to state a claim upon which relief
can be granted. The motion was granted and the physician appealed.

The Ninth Circuit reversed and remanded, finding that the district court erred
in “not applying the ordinary rules for assessing the sufficiency of a
complaint.” The Ninth Circuit held that, in order to survive a 12(b)(6)
motion to dismiss, a complaint asserting a claim for employment discrimination
pursuant to 42 U.S.C. §1981 “must contain only ‘a short and plaint
statement of the claim showing that the pleader is entitled to relief.'” Because
the district court had assessed the sufficiency of the physician’s complaint
based on a heightened pleading standard, the Ninth Circuit reversed and remanded
back to the district court for further consideration.