Henry v. Adventist Health Castle Medical Center, No. 19-16010 (9th Cir. 2020)
Annotate this CaseThe Ninth Circuit affirmed the district court's adverse grant of summary judgment against plaintiff's Title VII lawsuit. The panel held that the undisputed facts clearly show that plaintiff was Castle's independent contractor and thus not entitled to Title VII protections. In this case, plaintiff was paid, taxed, and received benefits like an independent contractor; plaintiff's obligations to Castle were limited, providing him the freedom to run his own private practice; the contracts between Castle and plaintiff described him as an independent contractor. The panel stated that other factors also weighed in favor of plaintiff being an independent contractor.
Court Description: Employment Discrimination. The panel affirmed the district court’s grant of summary judgment in favor of the defendant in a Title VII action brought by a surgeon who provided on-call service in a hospital emergency department. The panel held that Title VII did not protect the surgeon because he was an independent contractor, not an employee of defendant Adventist Health Castle Medical Center. The panel considered the surgeon’s payment arrangement, his limited obligations to Castle, and his description as an independent contractor in the parties’ contracts. The panel concluded that other factors, including the surgeon’s high skill level, Castle’s provision of assistants and medical equipment, and its mandatory professional standards, did not weigh strongly in the surgeon’s favor.
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