Third Circuit Affirms Judgment for Temple University Hospital in Race Discrimination Case

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Michael J. Fortunato,

December 4, 2019

On December 3, 2019, the U.S. Court of Appeals for the Third Circuit affirmed a decision of Judge John R. Padova of the Eastern District of Pennsylvania granting summary judgment in favor of Temple University Hospital and several of its physicians. The Third Circuit found that Plaintiff, Dr. Rao Mandalapu, a former urology resident at Temple, failed to prove that Temple’s legitimate and non-discriminatory reason for not promoting him to his next year of residency was pretextual.

In 2012, Temple refused to promote Mandalapu to the next level in its urology program. Temple based the decision on the judgment of several supervising physicians who believed that Mandalapu lacked the qualifications and skills necessary to continue as a resident.

In 2015, Mandalapu sued Temple and eight of his former supervising physicians, asserting that his dismissal amounted to race discrimination and retaliation under 42 U.S.C. § 1981. In 2018, Judge Padova awarded summary judgment in favor of Temple. Judge Padova found that Mandalapu was not qualified for a promotion, and therefore, he was unable to establish a prima facie case of discrimination. With respect to his retaliation claims, the Court found that Mandalapu failed to demonstrate any causal connection between any alleged protected activity and any adverse actions. Additionally, Mandalapu’s hostile work environment claim failed because he was unable to demonstrate that any reference or comments related to his accent were severe or pervasive. Finally, the district court ruled that Mandalapu did not marshal enough evidence to show that Temple’s reason for not promoting him was pretextual.

In affirming the district court’s ruling, the Third Circuit explained that:

“None of the evidence he [Mandalapu] provided undermines the credibility of their [Temple] stated reason for the decision to not renew his contract. The District Court correctly held that Mandalapu did not come forward with enough evidence for a reasonable juror to disbelieve that he was terminated for substandard performance. We conclude, for the same reason, that Mandalapu failed to carry his evidentiary burden.”

Michael J. Fortunato, Jason K. Roberts, and Cynthia B. Morgan represented Temple and its physicians in this case, captioned Rao S. Mandalapu, MD v. Temple University Hospital, et al., No. 18-2720 (3d Cir. December 3, 2019).

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