Evans v. Vanderbilt University School of Medicine
3:21-cv-00439
M.D. Tenn.Mar 4, 2022Background
- Plaintiff Brent Evans, a Vanderbilt University Medical School student with a long‑standing diagnosis of Major Depressive Disorder, experienced a severe relapse in 2012 that led to missed clinical shifts, remediation struggles, probation, and intermittent medical leaves.
- Evans received accommodations paperwork from Vanderbilt’s EAD in February 2013 and was granted a medical leave in March 2013; he later returned, struggled academically, and was dismissed by the Promotions Committee in February 2017, upheld on appeal April 3, 2017; a Faculty Senate grievance hearing occurred October 2018 and its final decision issued June 5, 2020.
- Evans filed suit June 4, 2021 asserting federal claims under the ADAAA and Rehabilitation Act and state claims for breach of express and implied contract, breach of the covenant of good faith and fair dealing, promissory estoppel, negligent misrepresentation, and negligent infliction of emotional distress.
- Defendants moved to dismiss under Rule 12(b)(6), arguing Evans’s federal claims are time‑barred and his state claims fail to plead enforceable promises or independent tort duties outside the alleged contractual relationship.
- The Court dismissed the federal ADA/RA claims as untimely (accrual at latest on April 3, 2017) and rejected continuing‑violation, equitable‑tolling, and equitable‑estoppel arguments; most state claims were also dismissed for failure to state plausible, contractually grounded violations or independent tort duties.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Accrual and statute of limitations for ADA/RA claims | Claims did not accrue until exhaustion of Vanderbilt internal remedies; Faculty Senate final decision June 5, 2020, so suit (June 4, 2021) is timely | Claims accrued at the injurious act (termination), at the latest April 3, 2017; plaintiff filed after limitations expired | Accrual occurred no later than April 3, 2017; federal claims time‑barred; dismissal under Rule 12(b)(6) appropriate |
| Continuing violation / equitable tolling / estoppel | Ongoing discrimination and lengthy internal process toll the limitations period; handbook language induced delay | Discrete acts govern; internal appeals do not toll limitations; handbook language does not promise or induce refraining from suit | Continuing‑violation inapplicable (no longstanding policy alleged); equitable tolling/estoppel denied — handbook language insufficient and plaintiff not diligent |
| Breach of contract (express/implied) and handbook timing | Handbook and university materials created contractual expectations (timely grievance process); implied contract breached by delays and failure to afford accommodations | Student handbook disclaims an express contract; handbook timing is aspirational ("usually") and academic decisions get deference; no specific contractual term shown | No express contract plausibly alleged; implied contract theory insufficiently tied to specific, enforceable obligations; handbook timing language not a contractual promise — breach claims dismissed |
| Negligent misrepresentation / NIED | Vanderbilt owed independent duties (e.g., doctor–patient or professional duties); tort claims distinct from contract claims | Negligence claims are repackaged contractual breaches; no separate duty pleaded; plaintiff abandoned or failed to allege medical malpractice | Tort claims dismissed: negligent claims subsumed by contract allegations and NIED requires independent proof; plaintiff failed to plead independent duty or required medical/expert proof |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must allege factual content that makes claims plausible under Rule 12(b)(6))
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for civil complaints)
- Sevier v. Turner, 742 F.2d 262 (6th Cir. 1984) (accrual standard: claim accrues when plaintiff knows or should know of injury)
- Jones v. R.R. Donnelley & Sons Co., 541 U.S. 369 (2004) (post‑1990 federal statutes governed by 28 U.S.C. § 1658 limitations period)
- Nat'l R.R. Passenger Corp. v. Morgan, 536 U.S. 101 (2002) (discrete discriminatory acts are not saved by continuing‑violation doctrine)
- Del. State Coll. v. Ricks, 449 U.S. 250 (1980) (pendency of internal grievance does not toll limitations for filing suit)
- Doherty v. S. Coll. of Optometry, 862 F.2d 570 (6th Cir. 1988) (student‑university relationship viewed as contractual, with judicial deference to academic decisions)
- Haithcock v. Frank, 958 F.2d 671 (6th Cir. 1992) (framework for continuing‑violation doctrine in Sixth Circuit)