Offor v. Mercy Med. Ctr. — Mar. 2016 (Summary)

EMPLOYMENT DISCRIMINATION

Offor v. Mercy Med. Ctr.
No. 15-CV-2219 (ADS)(SIL) (E.D.N.Y. Mar. 10, 2016)

The United States District Court for the Eastern District of New York granted a medical center’s motion to dismiss claims of national origin and race discrimination, retaliation, libel, slander, and intentional infliction of emotional distress made by a physician. The physician was an African American woman born in Nigeria. Among other things, the physician was denied moonlighting hours, not invited to a training class, denied vacation time, and demoted due to low volume.  Eventually, she was terminated due to unprofessional behavior and improper advice given to parents of a patient. In assessing the claims made by the physician, the court ruled that some of the medical center’s actions did not rise to the level of an “adverse action.”  Also, the physician relied solely on conclusory allegations without providing any sufficient factual allegations from which a jury could plausibly conclude that the medical center’s actions were based on her status as an African American.