Nwaneri v. George Washington University Hospital

CourtDistrict Court, District of Columbia
DecidedMarch 20, 2023
DocketCivil Action No. 2022-0821
StatusPublished

This text of Nwaneri v. George Washington University Hospital (Nwaneri v. George Washington University Hospital) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nwaneri v. George Washington University Hospital, (D.D.C. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

NGOZIKA J. NWANERI, Plaintiff,

v. Civil Action No. 22-821 (JDB)

GEORGE WASHINGTON UNIVERSITY HOSPITAL, Defendant.

MEMORANDUM OPINION

This dispute arises out of a surgery performed in August 2017 by the plaintiff, Dr. Ngozika

Nwaneri, at George Washington University Hospital (“GWUH”). The patient suffered from a

non-fatal adverse event during the surgery. GWUH then initiated a peer review of Nwaneri’s

surgery, which set in motion a chain of events that culminated in the suspension of Nwaneri’s

surgical privileges. Nwaneri alleges that GWUH mishandled the fallout from the surgery, and in

doing so, breached his employment contract, tortiously interfered with his business relations, and

discriminated against him. GWUH argues, among other things, that his claims are time barred.

For the reasons set forth below, the Court agrees that Nwaneri’s claims are untimely and will

dismiss the case.

Background

I. Factual Background 1

Nwaneri is “an elder African-American member in the Surgery Department” at GWUH

“with a career practice in cardiac, thoracic[,] and vascular surgery.” Compl. [ECF No. 28] (“Am.

1 The facts are drawn from Nwaneri’s proposed amended complaint because the majority of this Opinion discusses claims brought in it. A court “must assume the truth of all well-pleaded factual allegations in the complaint” at this stage. In re Harman Int’l Indus., Inc. Sec. Litig., 791 F.3d 90, 99 (D.C. Cir. 2015).

1 Compl.”) ¶ 1. He has been a surgeon for almost four decades and has had a “contractual

relationship with GWUH” since 2002. Id. ¶ 5. Starting in 2010, he began noticing a “pattern of

disparate treatment and discrimination”—including “two frivolous suspensions of vascular

privileges”—which he believes was based on “his age, race, and color.” Id. ¶ 6.

On August 21 and 22, 2017, Nwaneri “was involved in a surgery during which a patient

suffered from an adverse intra-operative bleeding event.” Am. Compl. ¶ 8. The patient survived

the adverse event and “was subsequently discharged in a satisfactory condition.” Id. On

September 19, 2017, a peer review committee met to review the incident and released an adverse

report a day later. Id. ¶ 9. Nwaneri alleges that this report “contained several errors,” which he

“attempted to address” but was unsuccessful. Id. The report formed the basis for “adverse

decisions” made by the Medical Executive Committee. Id.

On September 21, 2017 Nwaneri tried to schedule a heart surgery but was informed that

his surgical privileges had been suspended. Am. Compl. ¶ 10. He had not been given notice of

the suspension, which he alleges was “a violation of section 6.3 of the bylaws.” Id. The problem

was cleared up a few days later when the Medical Director “denied any restriction of Dr. Nwaneri’s

privileges,” and Nwaneri performed the heart surgery on September 26. Id. ¶ 11.

On October 4, 2017, Nwaneri met with the Medical Director and the Chairman of the

Department of Surgery. Am. Compl. ¶ 12. The Chairman gave Nwaneri an “ultimatum to resign”

(which he declined), referred to Nwaneri’s age, and “broadly threaten[ed] retaliation.” Id.

The Medical Executive Committee suspended Nwaneri’s privileges on October 16, 2017.

Am. Compl. ¶ 13. He appealed this decision a week later, and an ad hoc committee met on

November 1, presumably to review his appeal, and produced a report shortly after. Id. ¶ 14.

Nwaneri alleges that the committee met “two days after the fourteen days required by bylaw

2 6.4.2.3.” Id. The Medical Director submitted the report to the Board of Trustees, which requested

a second review. Id. ¶ 16. That review was completed and sent back to the Board of Trustees by

December 12, 2017. Id. On that date, “the Board of Trustees permanently affirmed revocation of

Dr. Nwaneri’s Vascular Surgery privileges,” “includ[ing] Cardiac and Thoracic Surgery

privileges . . . in violation of the bylaws section 6.4.” Id. ¶ 17. He was notified of the revocation

on December 14. Id.

A separate committee, the “Fair Hearing Committee,” which appears to have the power to

reject or accept the Board of Trustee’s action, see Am. Compl. ¶¶ 18, 21, convened on April 25,

2018, id. ¶ 18. Nwaneri alleges that the proceeding was “required to take place within 60 days or

before February 12, 2018” under bylaw section 6.5.2.1. Id. The committee’s report was also

allegedly filed late: under bylaw section 6.5.2.3, the committee should have submitted its report

by August 29, 2018 but did not submit it until October 30, 2018. Id. The report was dated

November 1, 2018, and Nwaneri’s privileges expired a day earlier, on October 31, 2018. Id. ¶ 20.

Nwaneri alleges that the “expiration of [his] privileges was premised on an erroneous

calculation of cases for re-credentialing and failure to automatically send [him] re-application

materials.” Am. Compl. ¶ 23. Specifically, GWUH should have “relied on cases performed 24

months prior to the privilege expiration” in October 2018, but instead “they relied on cases from

2018 alone.” Id.

The Fair Hearing Committee’s report “rejected the GWUH adverse action,” restored all of

Nwaneri’s surgery privileges, and recommended that he perform 30 supervised cases. Am. Compl.

¶ 21. Nwaneri appealed this report to the Appellate Panel. Id. ¶ 22. The Appellate Panel met to

consider his appeal on May 23, 2019, which he alleges was six months overdue under bylaw

3 section 6.6.2.1. Id. In June, the Appellate Panel reduced the number of supervised cases to 10.

Id.

Separately, on November 9, 2017, GWUH had “issued a skewed report to the National

Practitioner Data Bank (‘NPDB’),” which discussed Nwaneri’s privileges to practice medicine.

Am. Compl. ¶ 19. Although the “erroneous and inflammatory” report was revised a year later,

during that year, the report “damaged Dr. Nwaneri’s professional reputation[] and precluded him

from work.” Id.

II. Procedural Background

Nwaneri filed an “inquiry” with the Equal Employment Opportunity Commission on April

30, 2021. See Compl. for a Civil Case [ECF No. 1] (“Compl.”) at 12. The EEOC, however,

determined that his claims were time-barred and issued a right-to-sue letter on February 1, 2022,

informing Nwaneri that he could bring a case in federal district court within 90 days. See Dismissal

& Notice of Rights [ECF No. 1-2]; Am. Compl. ¶ 25.

Nwaneri brought this action pro se on March 25, 2022, alleging retaliation and

discrimination in violation of Title VII of the Civil Rights Act (“Title VII”) and the Age

Discrimination in Employment Act of 1964 (“ADEA”). See Compl at 1–3. GWUH filed a motion

to dismiss his claims in May 2022, arguing that Nwaneri did not “timely pursue his administrative

remedies and timely file a Charge of Discrimination” with the EEOC and that he failed to state a

claim under either Title VII or the ADEA. Def.’s Mot. to Dismiss Compl. [ECF No. 15] (“Mot.

to Dismiss”) at 2. Nwaneri opposed that motion, see Pl.’s Opp’n to Mot. to Dismiss [ECF No.

21], and GWUH filed a reply in support of its motion, see Def.’s Reply to Pl.’s Opp’n to Mot. to

Dismiss [ECF No. 23].

Despite the motion to dismiss being fully briefed, Nwaneri filed a motion seeking to amend

his complaint.

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