Knapik v. Mary Hitchcock Mem’l Hosp. (Summary)

RESIDENT DISCIPLINE

Knapik v. Mary Hitchcock Mem’l Hosp., No. 5:12-cv-175 (D. Vt. Feb. 3, 2015)

The U.S. District Court for the District of Vermont granted summary judgment to a hospital to resolve claims that the hospital wrongfully terminated a resident after she shared a colleague’s reprimand letter with a medical fellowship program.

The resident practiced at the Vermont hospital through the course of her residency. During this time, she befriended a resident colleague, though their relationship cooled after a series of disputes. At one time during her residency, the colleague received a letter from the Vermont hospital administration, reprimanding her and instructing her to change her behavior. When the colleague eventually applied for a fellowship position at a Kentucky hospital, she failed to disclose the contents of this letter. The resident, who had been shown this letter, anonymously sent the Kentucky hospital a copy of the letter. When the Vermont hospital was made aware of this, it traced computer inquiries to determine that the resident had sent the letter. After determining that her behavior was in violation of its ethical conduct standard, the Vermont hospital dismissed the resident from the residency program. The resident filed for wrongful termination, breach of contract, and breach of implied covenant of good faith and fair dealing.

The court declined to grant the hospital summary judgment on its claim that the resident failed to exhaust all remedies, finding that the hospital failed to follow its own policy for pursuing grievances. According to the hospital policy, the resident was to be given five days’ notice and the opportunity to request a hearing. However, the court found that the dismissal of the resident was within the hospital’s discretionary judgment. The court granted the hospital’s motion for summary judgment in deference to the hospital’s academic decision, finding that the dismissal was not arbitrary, capricious, or unreasonable.