Torchia v. Cmty. Health Care, Inc. (Summary)

DISCRIMINATION/BREACH OF CONTRACT

Torchia v. Cmty. Health Care, Inc., No. 12-5607 (D. N.J. Sept. 30, 2014)

The United States District Court for the District of New Jersey granted a health network’s motion for summary judgment against claims of employment discrimination and breach of contract filed by the former medical director. The medical director claimed that the CEO harassed her and made discriminatory remarks about her age, gender, national heritage, and religion.

The court concluded that the medical director did not present sufficient proof to infer that discrimination was the cause of her termination. It was unconvinced that her age or gender played a role in her termination, since the person who replaced her was a female over the age of 40. The court also found that her claims of discrimination based on national heritage and religion were implausible, since the local community demographics predominantly matched her Italian heritage and her Christian religion. This was further supported by the fact that the hospital hired most of its employees from the local community.

The court instead reasoned that the CEO harassed and bullied the medical director because he felt threatened that she would succeed him in his position, and explained that this evidenced more of a professional power struggle rather than discrimination based on the medical director’s personal characteristics. Although the court did consider the CEO’s comments to be unprofessional, it disagreed with the medical director’s arguments about any discriminatory motivations. The court relied heavily on the fact that ninety percent of the employees at the hospital were women and that the majority of professional and managerial employees were female.

Regarding the claim of breach of contract, the court explained that while the CEO’s alleged conduct may have felt egregious in the eyes of the medical director, it did not amount to the level of “outrageous, coercive, and unconscionable” behavior necessary to force a reasonable person to resign. As a result, the CEO’s behavior did not force the medical director to resign and therefore did not support a breach of contract claim.