Nadendla v. WakeMed, No. 21-1300 (4th Cir. 2022)Annotate this Case
Nadendla, a physician, is of Indian origin. Nadendla was a member of WakeMed’s hospital's medical staff where she was granted clinical privileges in 2010, In 2017, citing “clinical concerns,” WakeMed informed Nadendla that she would not be reappointed clinical privileges; her appointment on the medical staff would expire. Nadendla requested a hearing, pursuant to the Bylaws. She alleges that WakeMed’s actions during the hearing process “exhibited an abject lack of fairness” and deprived her of adequate process in contravention of the Bylaws.
Nadendla sued the hospital under 42 U.S.C. 1981, which guarantees to all persons in the United States “the same right . . . to make and enforce contracts . . . as is enjoyed by white citizens.’” The district court initially ruled that Nadendla sufficiently stated a section 1981 claim and state-law claims for breach of contract and for arbitrary and capricious conduct, but subsequently dismissed Nadendla’s section 1981 claim. The Fourth Circuit affirmed in part. The district court had the discretion to revisit its prior order and did not abuse its discretion in doing so. The complaint contained extensive, specific allegations regarding WakeMed’s failure to abide by the Bylaws but details regarding race are conspicuously absent. The court reversed the dismissal of Nadendla’s claim for breach of the implied covenant of good faith and fair dealing.