Court Grants VA Summary Judgment in Retaliatory Hostile Work Environment Case
The United States District Court for the Middle District of Florida granted summary judgment in favor of the Department of Veterans Affairs, finding that a physician failed to establish a retaliatory hostile work environment. Although the physician – an interventional cardiologist – was suspended three times and ultimately had her clinical privileges reduced, the court concluded that these actions were based on documented clinical concerns rather than retaliation for engaging in protected activity under Title VII. The court further noted the absence of a causal connection and found that the temporal gap between the physician’s protected activity and the disciplinary actions was too great to support her claims. Katakuri v. Dept. of Veterans Affairs
Court Denies Motion to Dismiss Retaliation Claims Following Resident’s Termination
The United States District Court for the Eastern District of New York partially denied a hospital’s motion to dismiss, allowing certain retaliation and “stigma‑plus” claims to proceed in a case brought by a former resident who was terminated from the hospital’s residency training program. The court concluded that the resident plausibly alleged retaliation by residency leadership, noting that the termination occurred shortly after supervisors became aware of formal discrimination complaints. Although the court acknowledged the program asserted non‑retaliatory reasons for the discharge, it found that the close temporal proximity to the complaints – along with alleged warnings against filing them – was sufficient to support a retaliation claim. El-Ghazaly v. Kim
Court Dismisses Disability Discrimination Claims
The United States District Court for the Central District of California adopted a Magistrate Judge’s report and recommendation and dismissed a complaint filed by a physician alleging disability discrimination against a hospital. The court dismissed the physician’s claims in part because the physician failed to state a claim for denial of a public accommodation under the Americans with Disabilities Act or the Rehabilitation Act. Ghobrial v. MemorialCare Long Beach Med. Ctr.