Pingree v. University of Utah
2:20-cv-00724
| D. Utah | Aug 15, 2025Background
- Dr. Rita Florian Pingree, a University of Utah medical school graduate, repeatedly failed to secure a residency at the University in internal medicine or radiology, coinciding with a contentious divorce which limited her geographic flexibility.
- Dr. Caroline Milne, University faculty, was integral to reviewing Pingree’s applications and allegedly made comments implying gender bias related to Pingree’s status as a single mother.
- Pingree accepted a one-year preliminary internal medicine position on Dr. Milne's oral assurance that high performance would lead to a categorical (full-residency) spot, but she was ultimately not promoted after the year.
- Pingree sued the University and Dr. Milne on multiple grounds: breach of contract, promissory estoppel, sex discrimination, retaliation, and constitutional claims; parties cross-moved for summary judgment.
- The court granted summary judgment to defendants on contract and due process claims, but found sufficient factual disputes for trial on promissory estoppel, equal protection (as to Milne), and sex discrimination/retaliation claims under Title IX and Title VII (retaliation only).
Issues
| Issue | Plaintiff’s Argument | Defendant’s Argument | Held |
|---|---|---|---|
| Breach of Contract (Residency Policies) | University breached policies by not offering contract renewal, process, or evaluation as required. | Policies only apply to categorical residents; Pingree was a preliminary intern. | Summary judgment for University; policies not applicable. |
| Promissory Estoppel | Milne orally promised advance to categorical residency if Pingree performed well, prompting Pingree’s reliance. | No reasonable reliance; written contract controlled; no clear promise. | Sufficient evidence for jury; summary judgment denied. |
| Equal Protection (Sex Discrimination) | Denied advancement due to gender stereotypes relating to single motherhood. | Actions were justified by performance and not gender-based. | Disputed facts and direct evidence for jury; summary judgment denied. |
| Retaliation (Title IX and Title VII) | Milne retaliated by delaying/casting doubt on recommendation letters after Pingree filed discrimination complaints. | Delays justified; no intent to retaliate; Pingree at fault for delays. | Jury could find for Pingree; summary judgment denied. |
| Due Process (Property or Liberty Interests) | Pingree had a property interest in continued residency; process was denied. | No protected interest; preliminary interns don’t have renewal rights. | Summary judgment for University/Milne; no protected interest. |
Key Cases Cited
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (discusses summary judgment standard)
- Board of Regents v. Roth, 408 U.S. 564 (defines property interests for due process)
- Price Waterhouse v. Hopkins, 490 U.S. 228 (discusses impermissibility of sex stereotyping in employment)
- City of Cleburne v. Cleburne Living Ctr., 473 U.S. 432 (applies rational basis for non-suspect classifications under Equal Protection)
- Trans World Airlines, Inc. v. Thurston, 469 U.S. 111 (discusses bypassing burden shifting with direct discrimination evidence)
- Jackson v. Birmingham Bd. of Educ., 544 U.S. 167 (Title IX covers retaliation)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for discrimination claims)