SULLIVAN v. THE UNIVERSITY OF NORTH CAROLINA HEALTH CARE SYSTEM

CourtDistrict Court, M.D. North Carolina
DecidedSeptember 29, 2025
Docket1:22-cv-00847
StatusUnknown

This text of SULLIVAN v. THE UNIVERSITY OF NORTH CAROLINA HEALTH CARE SYSTEM (SULLIVAN v. THE UNIVERSITY OF NORTH CAROLINA HEALTH CARE SYSTEM) is published on Counsel Stack Legal Research, covering District Court, M.D. North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
SULLIVAN v. THE UNIVERSITY OF NORTH CAROLINA HEALTH CARE SYSTEM, (M.D.N.C. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA

JOHN D. SULLIVAN, ) ) Plaintiff, ) ) v. ) 1:22-CV-847 ) THE UNIVERSITY OF NORTH ) CAROLINA HEALTH CARE ) SYSTEM, ) ) Defendant. )

MEMORANDUM OPINION AND ORDER

Catherine C. Eagles, Chief District Judge.

John Sullivan filed suit against the University of North Carolina Health Care System asserting that he was first demoted and later not promoted in violation of the Age Discrimination in Employment Act. His claim based on a 2019 demotion was dismissed for failure to exhaust administrative remedies. UNC Health now moves for summary judgment on the remaining claim, Doc. 55, based on allegations that UNC Health denied him a promotion in April 2021 because of his age. Because Mr. Sullivan has not presented evidence from which a factfinder could conclude that age discrimination was the reason he was not promoted, UNC Health’s motion will be granted. Mr. Sullivan also moves to amend his complaint to add a retaliation claim. Doc. 86. Because he delayed filing the motion until well after the deadline in the scheduling order, despite knowledge of the alleged facts supporting that claim, he has not shown good cause. The motion to amend will be denied. I. Facts All facts and reasonable inferences therefrom are stated in the light most favorable

to the non-movant, Mr. Sullivan. See generally Landholt v. Corley, 149 F.4th 486, 489 (4th Cir. 2025). Mr. Sullivan began work for UNC Health in 2017 in the Supply Chain department. Doc. 56-1 at 15–16. As part of a 2019 reorganization, UNC Health created the new position of System Director of Strategic Sourcing. Doc. 56-2 at ¶ 15. Mr. Sullivan and others applied. Doc. 56-1 at 52–53, 54. The position was not filled, and the job listing

was cancelled in 2020. Id. at 54–55; Doc. 56-2 at ¶ 17. Later, in December 2020, UNC Health sought applicants for the new position of Director of Sourcing and Contracting. Doc. 56-2 at ¶ 20; Doc. 56-1 at 60. Sullivan, then approximately 60 years old, applied. Doc. 21 at ¶ 27; Doc. 56-1 at 59, 61. A hiring committee interviewed Sullivan and two other applicants. Doc. 56-2 at ¶ 23–24. All

committee members used a rating grid to rate the three candidates, and Mr. Sullivan scored much lower than the other two. Id. at ¶ 26–27. One of the other candidates, J.V.D., was offered the position and he accepted. Id. at ¶ 35. J.V.D. was 44 years old at the time. Doc. 21 at ¶ 27. Additional facts and evidence will be discussed in connection with specific issues.

II. The Age Discrimination Failure to Promote Claim Under the ADEA, it is unlawful for an employer “to fail or refuse to hire or to discharge any individual or otherwise discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s age.” 29 U.S.C. § 623(a). “[A]n employee may make out an ADEA claim using either direct or circumstantial evidence.” Westmoreland v. TWC Admin. LLC, 924

F.3d 718, 725 (4th Cir. 2019). Claims grounded in circumstantial evidence are analyzed using the familiar McDonnell Douglas burden-shifting framework. Id. To establish a prima facie case of discrimination under the ADEA in a failure to promote claim, a plaintiff must establish: (1) he was a member of a protected class; (2) he applied for an open position and was qualified; (3) he was not promoted despite his qualifications; and (4) he was denied promotion under circumstances that create an

inference of unlawful discrimination. See Laber v. Harvey, 438 F.3d 404, 430 (4th Cir. 2006). In failure to promote cases, the Fourth Circuit construes the fourth prong to require a showing that “the position remained open or was filled by a similarly qualified applicant who was substantially younger than the plaintiff, whether within or outside the class protected by the ADEA.” Id.; see also Bandy v. City of Salem, 59 F.4th 705, 712 n.3

(4th Cir. 2023) (noting that plaintiffs in ADEA discriminatory discharge cases are required to show that the hired individual was substantially younger and comparably qualified). A. There is no direct evidence of discrimination. Direct evidence of age discrimination is shown when the employer “announced, or

admitted, or otherwise unmistakably indicated that age was a determining factor.” Palmer, 72 F.4th at 63 (cleaned up). Mr. Sullivan testified that none of the supervisors or members of the interview committee ever made a derogatory remark about age, much less one that bears on the promotion decision. Doc. 56-1 at 66–70. He has presented no direct evidence of conduct or statements reflecting a discriminatory attitude or that bear directly on the promotion decision at issue. Since his claim is based on circumstantial

evidence, the McDonnell Douglas framework applies. Westmoreland, 924 F.3d at 725. B. The circumstantial evidence does not create any disputed questions of material fact.

For purposes of this motion, UNC Health concedes that Sullivan has made a prima facie showing of discrimination. Doc. 57 at 13. Sullivan met the minimum qualifications for the Sourcing and Contracting role, Doc. 56-2 at ¶ 23, and, at the time of the promotion, he was 60 years old, while J.V.D. was 44. Doc. 21 at ¶ 27. UNC Health has presented evidence of a legitimate, nondiscriminatory reason for its actions. Everyone on the hiring committee rated Mr. Sullivan lower than the other two applicants based on the criteria established for the position. Doc. 56-2 at ¶ 27. Those criteria encompassed skills related to the position like technical knowledge, decision making, and planning and organizing. Id. at ¶¶ 29–30. Internal emails from the time show that the hiring decision was based on the assessment of a committee consisting of Mr. Sullivan’s peers and supervisors in the Supply Chain department, as well as the hiring

manager, all of whom unanimously favored J.V.D. for the job. Id. at ¶¶ 35–36. When the defendant makes a showing of a legitimate non-discriminatory basis for the decision not to promote the plaintiff, the burden shifts back to the plaintiff to show that those reasons are pretextual. Palmer, 72 F.4th at 63. When an employer articulates a legitimate, non-discriminatory basis for its action, courts generally do not “decide

whether the reason was wise, fair, or even correct, ultimately, so long as it truly was the true reason for the adverse employment action.” Hawkins v. PepsiCo, Inc., 203 F.3d 274, 279 (4th Cir. 2000) (cleaned up).

Here, Mr. Sullivan has not presented evidence of pretext sufficient to give rise to an inference that but for age discrimination, UNC Health would have promoted him. Mr. Sullivan contends in his brief that the hiring process was “riddled with irregularities,” Doc. 87 at 21, but at his deposition he testified that he was not aware of any deviations from its normal hiring process. Doc. 88-3 at 44. In any event, none of these supposed irregularities give rise to an inference of

pretext. “The mere fact that an employer failed to follow its own internal procedures does not necessarily suggest that the employer was motivated by illegal discriminatory intent.” Barnes v. Charles Cnty. Pub. Schs., 747 F. App’x. 115, 118 (4th Cir. 2018) (per curiam) (cleaned up). Instead, “there must be some evidence that the irregularity directly and uniquely disadvantaged a protected employee.” Id. (cleaned up). A plaintiff cannot

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Bluebook (online)
SULLIVAN v. THE UNIVERSITY OF NORTH CAROLINA HEALTH CARE SYSTEM, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sullivan-v-the-university-of-north-carolina-health-care-system-ncmd-2025.