Rhodes v. Sutter Health (Summary)

CORPORATE PRACTICE OF MEDICINE

Rhodes v. Sutter Health, No. CIV 2:12-0013 WBS DAD (E.D. Cal. Feb. 1, 2013)

The United States District Court for the Eastern District of California granted in part and denied in part a non-profit clinic’s motion for summary judgment.  A physician brought suit against the clinic and a medical group practice for a number of claims after her termination.  She argued that the medical group and the clinic should be treated as either joint employers or as one singular, integrated employer.

The district court held that the clinic should not be considered liable as a joint employer.  The clinic had little control over the day-to-day activities of the physician.  She was operating under her own license and did not have a supervisor.  The staff members of the clinic provided evaluations but only at the request of the medical group.  The court stated that assistance and support of an employer is not sufficient to demonstrate the control necessary of a joint employer.

The district court also held that the clinic and the medical group should not be treated as an “integrated enterprise.”  The court stated that it would be a mistake for a corporate entity to face liability for another entity’s acts simply because the two have a contract to provide services.  The relationship between the medical group and the clinic was meant to satisfy a state law prohibiting corporations from practicing medicine.