Savas v. William Beaumont Hosp.,
No. 01-72389 (E.D. Mich. Aug. 13, 2002)

An interventional cardiologist sued the hospital that suspended her clinical privileges following an investigation. The cardiologist claimed that the suspension was discriminatory and was actually based upon her gender and was in retaliation for her having reported sexual harassment. The U.S. District Court for the Eastern District of Michigan dismissed all claims against the hospital. The court noted that an employment relationship is an essential prerequisite to maintaining a claim under the Civil Rights Act of 1964 and that, based on the "economic realities test," the cardiologist's relationship to the hospital was that of an independent contractor rather than an employee.