Pal v. Jersey City Med. Ctr. (Summary)

HCQIA IMMUNITY

Pal v. Jersey City Med. Ctr., No. 11-6911 (SRC) (D. N.J. Oct. 24, 2014)

The United States District Court for the District of New Jersey granted a renewed motion for summary judgment filed by Jersey City Medical Center and an affiliated physician in a discrimination case brought by a female physician of Indian origin. The physician argued that her application for privileges was denied on account of her gender and national origin. She sued the medical center and affiliated physician for breach of contract, defamation, and a conspiracy to violate her civil rights.

The district court concluded that her breach of contract and defamation claims were barred by the Health Care Quality Improvement Act of 1986 (“HCQIA”), which grants limited immunity from suits from money damages to participants in certain professional peer review actions. The court explained that denial of her application was considered to be a “qualified professional peer review action” under the HCQIA, and noted that she had failed to demonstrate that the other physicians acted improperly with regard to her application.

The district court also held that the record did not support a civil rights conspiracy claim, since there was no evidence indicating a conspiracy to deny her application for a discriminatory purpose.