Plaintiff Dr. Matthew Byrnes sued defendants St. Catherine Hospital and Centura Health Corporation in the United States District Court for the District of Kansas, raising claims of retaliation under Title VII and the Americans with Disabilities Act (ADA), as well as state law claims. Before the court is Defendants’ motion for summary judgment.
Statement of Undisputed Facts
Dr. Byrnes worked as a surgeon and intensivist at St. Catherine Hospital (SCH) in Garden City, Kansas, from 2012 until February 12, 2020. He also served as SCH’s Chief Medical Officer from 2013 to 2019. In August 2019, Dr. Byrnes submitted a written complaint alleging sexual harassment and other misconduct by Dr. Kurt Kessler. The Medical Executive Committee (MEC) investigated the allegations and later requested that Dr. Byrnes undergo a psychological evaluation, which he opposed in January 2020.
In January 2020, SCH received a subpoena from the Kansas Board of Healing Arts (KBHA) regarding an anonymous complaint filed against Dr. Byrnes. Centura’s in-house counsel initiated an internal investigation in response. On February 12, 2020, Dr. Byrnes was terminated from his employment without cause. After his termination, SCH submitted Reports of Adverse Findings on several of Dr. Byrnes’ cases to the KBHA.
Legal Analysis
Title VII Retaliation Claims
Termination-Based Retaliation: The court applied the McDonnell Douglas burden-shifting framework to analyze Dr. Byrnes’ claim that he was fired in retaliation for his complaints about Dr. Kessler. The court found that Dr. Byrnes established a prima facie case of retaliation but ultimately failed to demonstrate that the defendants’ proffered reasons for termination were pretextual.
Review Process Retaliation: Dr. Byrnes also claimed that the defendants retaliated against him through their peer review process and reporting to the KBHA. The court concluded that Dr. Byrnes failed to establish the requisite causal connection between his protected activities and the adverse actions.
ADA Claims
“Regarded As” Disability Discrimination: The court found that Dr. Byrnes failed to establish a prima facie case for his claim that the defendants perceived him as having a mental disability and fired him on that basis.
ADA Retaliation: The court determined that Dr. Byrnes’ ADA retaliation claim, based on his filing of EEOC charges, failed to establish the necessary causal connection between the protected activity and the adverse actions.
State Law Claims: The court declined to exercise supplemental jurisdiction over Dr. Byrnes’ state law claims after dismissing all federal claims.
The court granted summary judgment to the defendants on all of Dr. Byrnes’ federal claims and dismissed the state law claims without prejudice.
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