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March 30, 2021

The Dominoes Continue to Fall: Teaching Hospitals Once Again Found Subject to Claims Under Title VII and Title IX for Sexual Discrimination and Retaliation

This Bulletin is brought to you by AHLA’s Medical Staff, Credentialing, and Peer Review Practice Group.
  • March 30, 2021
  • Beth Anne Jackson , Brown & Fortunato PC

In Castro v. Yale Univ., the U.S. District Court for the District of Connecticut denied motions to dismiss the claims of six female physician plaintiffs against Yale University and Yale New Haven Hospital (YNHH) for alleged sex-based discrimination and retaliation under both Title VII of the Civil Rights Act of 1964 (Title VII) and Title IX of the Education Amendment Act of 1972 (Title IX). Some of the plaintiffs were attending physicians and assistant professors or faculty members, and others were residents. Notably, the Castro decision moves the law forward on two issues: whether a teaching hospital is subject to Title IX, and whether employees of a teaching hospital can assert claims for sex-based discrimination and retaliation under both Title IX and Title VII. From a practical standpoint, the case highlights the potential risks of traditional hospital medical staff methods of dealing with problematic physician behavior when a residency program is involved.

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