Lee Davis v. Jefferson Hospital Association
2012 U.S. App. LEXIS 14243
| 8th Cir. | 2012Background
- Davis, an African-American cardiologist, obtained JRMC medical staff privileges in 2003.
- JRMC’s credentialing policy states privileges are granted by the hospital, not a right, and contingent on compliance with bylaws and rules.
- Between 2004–2006, Davis faced multiple complaints for abusive language and conduct toward JRMC staff.
- JRMC’s Credentials Committee and Ad Hoc Committee investigated Davis; findings included poor patient-care metrics and documentation, leading to a corrective action plan and suspensions.
- Davis’s privileges were eventually revoked after multiple investigations and hearings, culminating in JRMC’s Board decision affirmed on review.
- Davis filed a federal suit asserting race discrimination, retaliation, and conspiracy; the district court granted summary judgment for defendants and denied a continuance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Race discrimination under §1981/ACRA | Davis; similarly situated non-African-Americans treated more leniently. | DefendantsShow legitimate, non-discriminatory reasons (conduct, care, documentation). | No genuine dispute of material fact; no evidence of discriminatory motive. |
| Retaliation under §1981/ACRA | Protected activity (Nov 2005 complaint) linked to later privilege revocation. | No causal link shown between protected activity and adverse action. | Insufficient causation; no retaliation shown. |
| Conspiracy under §1985(3) | Defendants conspired to deprive him of rights due to race. | No racially discriminatory animus proven; no agreement shown. | Conspiracy claim fails as a matter of law. |
| Motion for continuance (discovery) | Needed discovery to oppose summary judgment. | No abuse of discretion; sufficient record for ruling. | District court did not abuse discretion; denial affirmed. |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. Supreme Court 1973) (foundation of burden-shifting in discrimination claims)
- Maxfield v. Cintas Corp. No. 2, 427 F.3d 544 (8th Cir. 2005) (prima facie case and shifting burden)
- Fields v. Shelter Mut. Ins. Co., 520 F.3d 859 (8th Cir. 2008) (similarly situated analysis for discrimination)
- Morgan v. A.G. Edwards & Sons, Inc., 486 F.3d 1034 (8th Cir. 2007) (requirements for evidence of pretext and discrimination)
- Larson by Larson v. Miller, 76 F.3d 1446 (8th Cir. 1996) (conspiracy elements under §1985(3) and need for particularized showing)
- City of Omaha Emps. Betterment Ass'n v. City of Omaha, 883 F.2d 650 (8th Cir. 1989) (animus requirement for class-based conspiracy claim)
- Hanks v. Prachar, 457 F.3d 774 (8th Cir. 2006) (affidavits and summary judgment standard; verified complaints equivalence)
- Frevert v. Ford Mtr. Co., 614 F.3d 473 (8th Cir. 2010) (need for probative evidence to defeat summary judgment)