Craig v. Yale University School of Medicine
2011 U.S. Dist. LEXIS 147354
D. Conn.2011Background
- Craig, an African-American male, was in Yale New Haven Hospital/Yale School of Medicine’s OB/GYN residency program starting June 2008.
- He was terminated from the program on December 15, 2008, with reinstatement on probation after a grievance process.
- Plaintiff alleges a pattern of racial and gender discrimination by program officials, including Norwitz and Shaw, and institutional defendants YNHH and YUSM.
- Plaintiff asserts seven counts (Title VII race, 1981 race, Title VII gender, breach of contract, IIED, and related claims) and that defendants moved to dismiss Counts 3 and 7.
- The court granted in part and denied in part the motions, dismissing Count Three’s pure gender claim but allowing a race-plus claim under Count One, and denying the IIED dismissal at this stage.
- Other counts and related assertions (e.g., Count Four and Count Six) are addressed later in the decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Pure gender discrimination claim viability | Craig argues race and gender discrimination are intertwined facts. | YNHH contends allegations of gender discrimination are conclusory or fail to state a pure gender claim. | Pure gender claim dismissed; race-plus claim survives under Count One. |
| Whether the race-plus (intersectional) claim is actionable | Craig contends 67% termination rate for African-American males shows race plus discrimination. | Defendants argue race-plus is not established for Title VII claims. | Race-plus discrimination plausibly supported; proceed under Count One. |
| IIED claim sufficiency | Craig argues conduct was extreme, outrageous, and caused severe distress in a residency context. | Defendants say conduct was not extreme or severe enough and distances from typical workplace distress. | IIED claim survives this stage; allegations plausibly support extreme conduct and severe distress. |
Key Cases Cited
- Jefferies v. Harris County Community Action Ass’n, 615 F.2d 1025 (5th Cir. 1980) (discrimination against black females can exist without discrimination against black men or white women)
- Kimble v. Wis. Department of Workforce Development, 690 F.Supp.2d 765 (E.D. Wis. 2010) (concept of race-plus discrimination recognized in Title VII context)
- Jeffers v. Thompson, 264 F.Supp.2d 314 (D. Md. 2003) (composite race-and-gender discrimination recognized when race and gender intertwined)
- Perodeau v. City of Hartford, 259 Conn. 729 (2002) (employment distress reasonable but not extreme or outrageous conduct)
- Appleton v. Bd. of Ed. of the Town of Stonington, 254 Conn. 205 (2000) (extreme and outrageous standard for IIED in Connecticut)