Reginald Williams v. Columbus Regional Healthcare Systems, Inc., 499 F. App'x 928

Williams, African-American male, sues under 42 U.S.C. §1981 alleging race-based interference with his rights to equal benefit of laws and to contract with third parties.
District court dismissed the complaint for failure to state a claim.
Defendants include Columbus Regional Healthcare Systems, Weldon, Morley, Hannay, and John Does A–J.
Court applies Jimenez v. WellStar Health System to require a protected right and intentional discrimination in a federally protected activity under §1981.
Suspension of medical staff privileges is not cognizable under §1981 because no contractual or property interest exists under Georgia law.
Court affirms the district court’s dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether suspension of medical staff privileges supports a §1981 claim	Williams argues privileges were interfered with under §1981	Appellees contend privilege suspension lacks a cognizable contractual/property interest	Affirmed
Whether Williams can state a §1981 claim based on interference with hospital contracts	Williams asserts interference with hospital/patient contracts	Appellees argue no valid contractual interest exists from privileges alone	Affirmed
Whether future employment contracts were improperly speculative	Williams seeks protection for possible future contracts	Appellees contend §1981 claim must involve existing rights	Affirmed
Whether any other §1981 rights were violated by the alleged bystander conduct	Williams relies on broader rights to equal benefit of laws	Appellees deny any injury to protected rights	Affirmed
Standard of review on dismissal	Not specifically contested	De novo review on Rule 12(b)(6) dismissals per Hill v. White	Affirmed (de novo review)

Jimenez v. WellStar Health System, 596 F.3d 1304 (11th Cir. 2010) (elements of §1981 non-employment discrimination; protected rights include equal benefit of laws and right to contract)