Satyanarayan Hegde v. Montefiore Medical Center; Albert Einstein College of Medicine; Raanan Arens; David Gozal; Recruitwell, LLC; Erin Brite; Alan Lamb; and Chris Noel

CourtDistrict Court, S.D. New York
DecidedJanuary 2, 2026
Docket1:25-cv-04222
StatusUnknown

This text of Satyanarayan Hegde v. Montefiore Medical Center; Albert Einstein College of Medicine; Raanan Arens; David Gozal; Recruitwell, LLC; Erin Brite; Alan Lamb; and Chris Noel (Satyanarayan Hegde v. Montefiore Medical Center; Albert Einstein College of Medicine; Raanan Arens; David Gozal; Recruitwell, LLC; Erin Brite; Alan Lamb; and Chris Noel) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Satyanarayan Hegde v. Montefiore Medical Center; Albert Einstein College of Medicine; Raanan Arens; David Gozal; Recruitwell, LLC; Erin Brite; Alan Lamb; and Chris Noel, (S.D.N.Y. 2026).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Satyanarayan Hegde, Plaintiff, -against- 25-cv-4222 (AS) Montefiore Medical Center; Albert Einstein

College of Medicine; Raanan Arens; David Gozal; Recruitwell, LLC; Erin Brite; Alan OPINION AND ORDER Lamb; and Chris Noel, Defendants.

ARUN SUBRAMANIAN, United States District Judge: After failing to get a job at a medical center, Satyanarayan Hegde sued an avalanche of parties, proceeding pro se. Before the Court are motions to dismiss filed by all defendants. For the reasons below, the Court GRANTS the motions to dismiss. BACKGROUND This story begins with Hegde’s application to the Department of Pediatrics at Montefiore Med- ical Center (which is affiliated with the Albert Einstein College of Medicine). Dkt. 5 ¶¶ 6–7, 14. A doctor at Montefiore named Raanan Arens was overseeing the hiring and wanted some more information about Hegde because he had changed jobs a lot. Id. at 61–62. He emailed a doctor who had previously worked with Hegde at the University of Chicago named David Gozal to ask about Hegde. Id. The reference wasn’t good. Gozal wrote that Hegde “is a very difficult personality and does not get along well with others; not a team player and creates tension in the division with other faculty and staff.” Id. at 61. Arens then decided not to hire Hegde. Id. ¶ 20. Hegde sued everybody involved. That includes Montefiore, Albert Einstein, Arens, Gozal, the recruiting agency that ran the process (Recruitwell), and a bunch of the agency’s employees. Hegde has one set of claims against all defendants: (1) that they violated the Fair Credit Reporting Act (FCRA) by getting and using the reference from Gozal; (2) that they defrauded him; and (3) that he was the victim of negligently misrepresented information. All defendants filed motions to dis- miss. LEGAL STANDARDS To survive a motion to dismiss brought under Rule 12(b)(6), “a complaint must contain suffi- cient factual matter, accepted as true, to state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (internal quotation marks omitted). “A claim has facial plausi- bility when the plaintiff pleads factual content that allows the court to draw the reasonable infer- ence that the defendant is liable for the misconduct alleged.” Id. In reviewing a motion to dismiss, a court “accept[s] all factual allegations as true, and draw[s] all reasonable inferences in the plain- tiff’s favor.” Austin v. Town of Farmington, 826 F.3d 622, 625 (2d Cir. 2016). Pro se complaints are subject to the same requirements but should be “construed liberally.” Fulton v. Goord, 591 F.3d 37, 42 n.1 (2d Cir. 2009). That said, “even from pro se plaintiffs, bald assertions and conclusions of law are not adequate to withstand a motion to dismiss.” Ruotolo v. Fannie Mae, 933 F. Supp. 2d 512, 524 (S.D.N.Y. 2013) (cleaned up). DISCUSSION I. There’s no “consumer report” here so the FCRA doesn’t apply Under the FCRA, “a person may not procure a consumer report … for employment pur- poses … unless … (i) a clear and conspicuous disclosure has been made in writing to the con- sumer … and (ii) the consumer has authorized in writing … the procurement of the report.” 15 U.S.C. § 1681b(b)(2)(A)(i–ii). A consumer report is: “any written, oral, or other communication of any information by a consumer reporting agency bearing on a consumer’s credit worthiness, credit standing, credit capacity, charac- ter, general reputation, personal characteristics, or mode of living which is used or expected to be used … for the purpose of serving as a factor in establishing the consumer’s eligibility for … employment purposes.” 15 U.S.C.§ 1681a(d)(1) (emphasis added). The italicized part is crucial. The FCRA applies only when a “consumer reporting agency” gives a reference. That’s a defined term in the statute. It means: “any person which, for monetary fees, dues, or on a cooperative nonprofit basis, regularly engages in whole or in part in the practice of assembling or evaluating consumer credit information or other information on consumers for the purpose of furnishing consumer re- ports to third parties….” 15 U.S.C. § 1681a(f). Hegde’s theory of the case is the Gozal (the doctor who gave the reference) is a consumer reporting agency and that his reference was a consumer report. That fails for five reasons. First, Hegde doesn’t allege that Gozal charged any fees or dues or that he was engaged “on a cooperative nonprofit basis.” Id. Second, he doesn’t allege that Gozal provided reports “regularly.” Id. Third, even if Gozal did this regularly, Hegde doesn’t allege that he did it regularly “for the purpose of furnishing consumer reports to third parties.” Id. Fourth, “to qualify as a ‘consumer reporting agency’ under the FCRA, an entity must specifically intend to furnish a ‘consumer report,’” Kidd v. Thomson Reuters Corp., 925 F.3d 99, 103 (2d Cir. 2019), and Hegde similarly makes no such allegation or argument about Gozal’s mental state. Fifth, even if Gozal is a consumer reporting agency, the FCRA has a carveout for any “report containing information solely as to … experi- ences between the consumer and the person making the report.” 15 U.S.C.§ 1681a(d)(2)(A)(i). Gozal’s reference (which Hegde attached to his complaint) described his experience in the work- place with Hegde and so falls into the safe harbor. All in all, Hegde fails to allege that Gozal meets any part of the definition of a “consumer reporting agency” or that he made a “consumer report.” Instead, he reads much of this language out of the statute when he recites the definition. Dkt. 27 at 4. So his FCRA claims are dismissed as against all defendants.1 II. Hegde can’t claim he was defrauded by anybody Hegde’s spaghetti-at-the wall theories of fraud are similarly unavailing. The idea is that Gozal lied in his reference with the intent that Montefiore rely on it and not hire Hegde, injuring him. Dkt. 5 ¶¶ 44–46. On top of that, Montefiore should have told Hegde about the negative reference. And further, what Montefiore (and Recruitwell) did tell him were lies. So, in Hegde’s words: “De- fendants intended to induce Plaintiff to cease further inquiry or challenge (which Plaintiff did, for a time, not knowing what had occurred), and to rely on the legitimacy of the hiring process out- come.” Dkt. 5 ¶ 45. None of these theories holds up. Gozal’s reference is at the core of this case—it’s Hegde’s central grievance with the entire process. But he can’t bootstrap a fraud claim from it. His theory of fraud based on misrepresenta- tion isn’t viable because the statement was made to somebody else and “a plaintiff does not estab- lish the reliance element of fraud for purposes of … New York law by showing only that a third party relied on a defendant’s false statements.” Cement & Concrete Workers Dist. Council Welfare Fund, Pension Fund, Legal Servs. Fund & Annuity Fund v. Lollo, 148 F.3d 194, 196 (2d Cir. 1998).

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Satyanarayan Hegde v. Montefiore Medical Center; Albert Einstein College of Medicine; Raanan Arens; David Gozal; Recruitwell, LLC; Erin Brite; Alan Lamb; and Chris Noel, Counsel Stack Legal Research, https://law.counselstack.com/opinion/satyanarayan-hegde-v-montefiore-medical-center-albert-einstein-college-of-nysd-2026.