Davis v. Jefferson Hosp. Ass’n

Dr. Lee Davis, an African-American cardiologist, obtained medical-staff privileges at Jefferson Regional Medical Center (JRMC). Later, JRMC's Board of Directors voted to revoke Davis's medical-staff privileges for poor quality of patient care, improper medical documentation, and unprofessional behavior. Davis filed the instant suit in federal district court, alleging, inter alia, race discrimination and retaliation, in violation of 42 U.S.C. 1981 and the Arkansas Civil Rights Act (ACRA), and conspiracy to interfere with his civil rights, in violation of 42 U.S.C. 1985(3). The district court granted summary judgment to Defendants, JRMC, its CEO, and several physicians (Defendants), and dismissed all of Davis's claims. The Eighth Circuit Court of Appeals affirmed, holding (1) because Davis failed to provide any evidence giving rise to an inference that Defendants racially discriminated against him, the district court did not err in granting summary judgment on Davis's race discrimination claims; (2) Davis failed to establish a prima facie case of retaliation under section 1981 and ACRA; and (3) the district court did not err in dismissing Davis's civil rights conspiracy claim pursuant to section 1985(3), as Davis failed to show any racial animus on the part of Defendants. View "Davis v. Jefferson Hosp. Ass'n " on Justia Law