Sanghvi v. St. Catherine's Hosp.,
Inc., No. 00-3613 (7th Cir. July 3, 2001)

After making multiple offers to purchase an obstetrics/gynecology practice for which he had worked since 1994, an Indiana physician of "Asian Indian ethnicity" claimed racial and ethnic discrimination and sued the hospital that owned the practice when the practice was sold to a physician group composed of "all white men." Affirming the District Court, the United States Court of Appeals for the Seventh Circuit applied the conventional method of analysis of a federal discrimination suit under §1981 to the dispute and held that, with the possible exception of one discriminatory statement allegedly made by the hospital's CEO, the direct and circumstantial evidence in the case would prevent any reasonable jury from concluding that the hospital's decision to sell the practice to the physician group was motivated by racial or ethnic discrimination. Although the physician was able to show that the hospital CEO made a statement that reflected "discriminatory animus," the court held that the alleged statement provided "no more than a scintilla of evidence of racial discrimination and [was] insufficient to permit a reasonable jury to return a verdict for the physician."

The court also applied a burden-shifting analysis and found that the hospital had presented sufficient business-related reasons to justify its decision not to sell the practice to the physician and as such, the physician could not cast sufficient doubt on the hospital's refusal to sell the practice to him to raise a triable issue as to pretext.