Mehta v. University of Rochester Medical Center

CourtDistrict Court, W.D. New York
DecidedFebruary 11, 2025
Docket6:21-cv-06299
StatusUnknown

This text of Mehta v. University of Rochester Medical Center (Mehta v. University of Rochester Medical Center) is published on Counsel Stack Legal Research, covering District Court, W.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mehta v. University of Rochester Medical Center, (W.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK

RUPAL MEHTA, M.D.,

Plaintiff, Case # 21-CV-6299-FPG v. DECISION AND ORDER

UNIVERSITY OF ROCHESTER MEDICAL CENTER,

Defendant.

INTRODUCTION Plaintiff Rupal Mehta brings this action against her former employer, University of Rochester Medical Center (“URMC”). ECF No. 1. She alleges that she suffered retaliation when she opposed URMC officials’ efforts to compel her to violate the conditions of a federal grant, and when she complained about gender discrimination. With respect to the former, Mehta asserts a claim under the antiretaliation provision of the False Claims Act (“FCA”), 31 U.S.C. § 3730(h), and with respect to the latter, she raises a claim under the New York State Human Rights Law (“NYSHRL”), N.Y. Exec. Law § 296. URMC now moves for summary judgment on both claims. ECF No. 45. For the reasons that follow, URMC’s motion for summary judgment is DENIED. LEGAL STANDARD Summary judgment is appropriate when the record shows that there is “no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a); see also Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986). Disputes concerning material facts are genuine where the evidence is such that a reasonable jury could return a verdict for the non-moving party. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). In deciding whether genuine issues of material fact exist, the court construes all facts in a light most favorable to the non-moving party and draws all reasonable inferences in the non-moving party’s favor. See Jeffreys v. City of New York, 426 F.3d 549, 553 (2d Cir. 2005). However, the non-moving party “may not rely on conclusory allegations or unsubstantiated speculation.” F.D.I.C. v. Great Am.

Ins. Co., 607 F.3d 288, 292 (2d Cir. 2010) (quotation omitted). BACKGROUND The summary-judgment record is extensive, and the parties proffer highly divergent versions of the underlying events. Given the standard of review, however, the Court will confine its discussion to the facts proffered by Mehta and taken in the light most favorable to her. In accordance with its limited role on summary judgment, the Court takes no view about the credibility of Mehta’s version of events. Mehta is a licensed and board-certified pathologist. See ECF No. 51-2 at 1. In 2011, she joined the faculty at the University of Maryland School of Medicine. See ECF No. 51-71 at 4. In 2014, Mehta received a “K08 career development research grant” from the National Institute of

Neurological Disorders and Stroke (“NINDS”)—an institute housed within the National Institutes of Health (“NIH”). ECF No. 51-2 at 2. NIH is a federal agency. The “K08” grant provides support so that research scientists can engage in a “sustained period of ‘protected time’ (generally three, four, or five years) for intensive research career development under the guidance of an experienced mentor or sponsor in the biomedical, behavioral, or clinical sciences.” ECF No. 45-16 at 5. A “K08” grantee must devote “a minimum commitment equivalent of 9 calendar person months (75% [of] their full-time appointment at the applicant institution) to the career development and research objectives of the program,” with the “remaining 3 person months (25% effort), if applicable, [] divided among other research, clinical, and teaching activities,” so long as those other activities are “consistent with the . . . [the grantee’s] development into an independent investigator.” Id. at 6. The K08 grant is conditioned on various reporting requirements, including the submission of progress reports. See id. at 7. Additionally, the institution hosting a K08 grantee must make certain commitments to ensure that the grant is

used in accordance with its objectives and conditions. See ECF No. 51-64; ECF No. 51-72 at 4. In July 2015, URMC hired Mehta as an assistant professor in its Department of Pathology and Laboratory Medicine, for a four-year appointment to end June 30, 2019. See ECF No. 45-2 ¶ 1. Bruce Smoller—the chair of URMC’s Pathology Department—submitted a letter to NIH affirming that URMC would honor the requirement that Mehta have “75% protected time for her research activities and career development.” ECF No. 51-22 at 2 (emphasis omitted). NIH transferred Mehta’s award to URMC in September 2015. See ECF No. 45-18 at 2. At that time, URMC began receiving Mehta’s grant funds from NIH, and it would ultimately receive over $600,000 in grants during the term of Mehta’s appointment. Id. at 34. Mehta asserts, and the Court must accept at this juncture, that during late 2015 and early

2016, Smoller and Brendan Boyce—vice chair of the Pathology Department—insisted that Mehta perform “clinical work that required vastly more than 25%” of her working time due to “under- staffing and other workflow problems in the autopsy division.” ECF No. 51-2 at 3; see also id. at 7-10; ECF No. 51-27 at 2 (January 2016 email from Mehta to Boyce and Smoller) (calculating that her clinical duties “comprised 35-40% of total month work hours”). Mehta repeatedly complained that the clinical obligations imposed on her were inconsistent with the conditions of her K08 grant. See ECF No. 51-27; ECF No. 51-29; ECF No. 51-30. Smoller became irate at Mehta’s complaints, see ECF No. 51-28 at 2, and in a letter dated March 9, 2016, impliedly threatened her continued professional progress at URMC should she maintain her objections to the current arrangement. See ECF No. 51-32 at 2-4 (asserting that Mehta’s “time at URMC is not off to a good and productive start”; that the “trajectory” needs to be “alter[ed]”; criticizing Mehta’s “niggling about exact times spent in one endeavor or another”; and alluding to the need to “turnaround the current momentum” of Mehta’s employment so that she can have a “long and

productive career” at URMC). As time went on, Mehta continued to request assistance from various URMC officials to alter her duties to conform to the grant requirements, to no avail. Several acknowledged that Mehta’s workload was inconsistent with her grant requirements, but believed the violations were necessary given the Pathology Department’s needs. See ECF No. 51-2 at 10-11, 12. There is evidence that Smoller was aggressive and intimidating to Mehta due to her complaints. At a meeting in early summer 2016, when Mehta again lobbied Smoller for relief from her extensive clinical work, Smoller “leaned back in his chair, thrust his crotch toward [Mehta] and told [her] to ‘suck it.’” ECF No. 51-2 at 10. Smoller soon suggested to Mehta that he was considering demoting her to a “full-time researcher” and reducing her salary accordingly. ECF No. 51-35 at

2. At another meeting, Smoller repeated his “suck it” insult and gesture, while telling Mehta that her treatment “was not any different from the way [she] would be treated ‘as an Asian woman’ elsewhere in academia.” ECF No. 51-2 at 13. Mehta’s struggle to induce URMC to abide by the grant requirements continued. In fall 2017, Mehta received confirmation from an NIH official that the responsibilities placed upon her did not conform to K08 grant requirements. See ECF No. 51-44.

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Mehta v. University of Rochester Medical Center, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mehta-v-university-of-rochester-medical-center-nywd-2025.