Phyllis Alston v. Thomas Jefferson University Hospitals

CourtCourt of Appeals for the Third Circuit
DecidedMarch 25, 2026
Docket25-1257
StatusUnpublished

This text of Phyllis Alston v. Thomas Jefferson University Hospitals (Phyllis Alston v. Thomas Jefferson University Hospitals) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Phyllis Alston v. Thomas Jefferson University Hospitals, (3d Cir. 2026).

Opinion

U.S. COURT OF APPEALS FOR THE THIRD CIRCUIT No. 25-1257

PHYLLIS M. ALSTON, Appellant

v.

THOMAS JEFFERSON UNIVERSITY HOSPITALS; LANKENAU MEDICAL CENTER; MAIN LINE HEALTH; CVS PHARMACY, INC. d/b/a SimpleDose; DR. SARA R. HEFTON, M.D.; et al. _____________________________ Appeal from U.S. District Court, E.D. Pa. Judge Kelley B. Hodge No. 2:24-cv-00093

Before: MATEY, FREEMAN, and CHUNG, Circuit Judges Submitted under Third Circuit L.A.R. 34.1(a) on Mar. 17, 2026 Decided: Mar. 25, 2026 _____________________________

NONPRECEDENTIAL OPINION*

CHUNG, Circuit Judge. Phyllis Alston brought state and federal law claims against several

defendants following the death of her mother, Margaret Morris, at Thomas Jefferson

University Hospital (“Jefferson Hospital” or “Jefferson”) in early 2022. On appeal, Alston

argues that the District Court erred and abused its discretion by dismissing her federal law

claims and denying her third request for a continuance to file the certificates of merit

required by Pennsylvania law. We will affirm.

I. BACKGROUND

* This disposition is not an opinion of the full Court and, under I.O.P. 5.7, is not binding precedent. Alston’s 91-year-old mother, Margaret Morris, suffered two seizures on Christmas Day

in 2021. She was brought to the Lankenau Medical Center and then to Jefferson Hospital.

A12. She passed away two weeks later, after suffering a stroke and heart attack. Alston

brought a civil action against Lankenau Medical Center, Jefferson, Main Line Health, CVS

Pharmacy, Inc., and several individual healthcare professionals (collectively,

“Defendants”). She alleged that they failed to provide Morris with proper care, leading to

her death. She further pled that the inadequate care Morris received was the product of

Defendants’ racial animus. Alston brought (1) a claim that Defendants violated Title VI

of the Civil Rights Act of 1964 and the Equal Protection Clause of the Fourteenth

Amendment; (2) a 42 U.S. § 1985(3) conspiracy claim; and (3) medical negligence claims

against Defendants under state law.2

Defendants filed motions to dismiss, after which Alston filed an Amended

Complaint in July of 2024. Defendants then filed respective motions to dismiss the

Amended Complaint. Alston sought multiple continuances to file the certificates of merit

in support of her state law claims, and her last continuance motion was denied. On

November 5, 2024, the District Court granted Defendants’ motions, dismissing the federal

claims and declining to exercise supplemental jurisdiction over the state law claims. In

December of 2024, Alston filed her state law claims in the Court of Common Pleas of

Philadelphia County. Meanwhile, Alston unsuccessfully moved the District Court to

reconsider its denial of her motion to continue the deadline for filing her certificates of

2 Alston does not appeal the dismissal of her state law claims. 2 merit. Alston timely appealed.

II. ANALYSIS2

A. Alston’s Federal Claims

Alston sued Defendants for violating Title VI, Section 1985(3), and the Equal

Protection Clause. All three claims fail.

First, Section 601 of Title VI states that “[n]o person in the United States shall, on the

ground of race, color, or national origin, be excluded from participation in, be denied the

benefits of, or be subjected to discrimination under any program or activity receiving

Federal financial assistance.” 42 U.S.C. § 2000d. Title VI requires a showing of

intentional discrimination, either through direct or circumstantial evidence. Alexander v.

Sandoval, 532 U.S. 275, 280 (2001); Pryor v. Nat’l Collegiate Athletic Ass’n., 288 F.3d

548, 563 (3d Cir. 2002).

Even construing the allegations in the light most favorable to Alston, the Amended

Complaint fails to allege, either through direct or circumstantial evidence, any form of

intentional discrimination. Alston alleges numerous acts of medical negligence and

contends that such negligence could only be the result of racial hostility. But she puts forth

no facts to support this contention, and her conclusory assertions that racial animus is the

2 The District Court had diversity jurisdiction pursuant to 28 U.S.C. § 1331 and supplemental jurisdiction over the state law claims pursuant to 28 U.S.C. § 1367(a). We have jurisdiction pursuant to 28 U.S.C. § 1291. We review a District Court’s decision to dismiss a complaint under Rule 12(b)(6) de novo. Keystone Redevelopment Partners, LLC v. Decker, 631 F.3d 89, 95 (3d Cir. 2011). We review a District Court’s refusal to exercise supplemental jurisdiction for abuse of discretion. Figueroa v. Buccaneer Hotel Inc., 188 F.3d 172, 175 (3d Cir. 1999). 3 only logical motivator of Defendants’ purportedly negligent treatment does not support a

plausible inference of discrimination. See Ashcroft v. Iqbal, 556 U.S. 662, 663 (2009)

(“[T]he tenet that a court must accept a complaint’s allegations as true is inapplicable to

threadbare recitals of a cause of action’s elements, supported by mere conclusory

statements.”).3

Second, Section 1985(3) conspiracy claims similarly require a showing “that the

decisionmaker … selected or reaffirmed a particular course of action at least in part

‘because of,’ not merely ‘in spite of,’ its adverse effects upon an identifiable group.” Bray

v. Alexandria Women’s Health Clinic, 506 U.S. 263, 272 (1993) (citations omitted).

Alston’s § 1985(3) claim fails on the merits for the same reason her Title VI claim fails:

she has failed to plausibly allege that Defendants’ actions were motivated by Morris’s race,

and therefore has failed to show that Defendants engaged in a particular course of action

“because of … its adverse effect[] upon” Morris as an African American. Id. The

Amended Complaint’s references to racial animus are merely Alston’s subjective

interpretations of the Defendants’ behaviors and motivations; they are not factual

allegations that allow for the reasonable inference that Defendants were motivated by racial

discrimination.

Last, Alston sued Defendants under § 1983 for violating the Equal Protection Clause of

3 Alston contends that intentional discrimination may be shown through deliberate indifference, Opening Br. 15–17, but even so, her complaint is devoid of any plausible allegation that Defendants engaged in, or had knowledge of, racial discrimination as required by that standard. Cf. Hall v. Millersville Univ., 22 F.4th 397, 410–11 (3d Cir. 2022) (discussing deliberate indifference standard in Title IX context). 4 the Fourteenth Amendment. That claim also fails.

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Related

Bray v. Alexandria Women's Health Clinic
506 U.S. 263 (Supreme Court, 1993)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Keystone Redevelopment Partners, LLC v. Decker
631 F.3d 89 (Third Circuit, 2011)
Leshko v. Servis
423 F.3d 337 (Third Circuit, 2005)
Chafin v. Chafin
133 S. Ct. 1017 (Supreme Court, 2013)
Alexander v. Sandoval
532 U.S. 275 (Supreme Court, 2001)
John Hall v. Millersville University
22 F.4th 397 (Third Circuit, 2022)
Figueroa v. Buccaneer Hotel Inc.
188 F.3d 172 (Third Circuit, 1999)

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