Stewart v. Am. Ass’n of Physician Specialists, Inc. — Nov. 2015 (Summary)

PROFESSIONAL ASSOCIATIONS

Stewart v. Am. Ass’n of Physician Specialists, Inc.
Case No. 5:13-cv-01670-ODW (DTBx) (C.D. Cal. Nov. 30, 2015)

The United States District Court for the Central District of California granted in part and denied in part a professional organization’s motion for summary judgment while denying a physician’s motion for summary judgment over claims arising from the termination of the physician’s membership from the organization.

The physician was notified that the organization would be holding a meeting of its Disciplinary Committee to consider charges against her of conduct injurious to the best interests of the organization. The physician did not attend the meeting, but sent a letter to each member of the organization’s Board refuting the charges. The physician also alleged that there was a conflict of interest due to the composition of the Disciplinary Committee, which would prevent a fair hearing from occurring. Ultimately, the Board voted to terminate the physician’s membership from the organization.

The physician alleged that the organization breached its contract with her, violated several civil rights laws, engaged in fraud, and defamed her, among other causes of action. The organization argued that the business judgment rule protected its decision to terminate the physician’s membership because the decision was based on the information available at the time, and was made in good faith. The court declined to grant summary judgment based on the business judgment rule because the physician’s allegations created enough of a factual dispute. Thus, the physician’s allegations of fraud, bad faith, and conflicts of interest were allowed to proceed. The court dismissed the physician’s civil rights claims under Title VII and the Fair Employment and Housing Act, but allowed her gender discrimination claims to go forward.