In Doe v. Mercy Catholic Medical Center, 2017 U.S. App. LEXIS 4004 (3d Cir. March 7), the U.S. Court of Appeals for the Third Circuit held that a former medical resident at a private Philadelphia hospital could bring a civil rights action under either Title VII of the Civil Rights Act of 1964 or Title IX of the Education Amendments of 1972. This decision has the potential to transform Title IX litigation and puts all employers who receive federal financial assistance on notice that Title IX and its procedurally specific mandates may apply to private employers who receive federal funds and engage in educational programs or activities.
Jane Doe, a medical resident at a private Philadelphia hospital, contended her supervisor sexually harassed her and dismissed her from the residency program after she formally complained to human resources. Instead of proceeding under Title VII of the Civil Rights Act of 1964, the traditional anti-discrimination statute, Doe relied on Title IX of the Education Amendments of 1972. This allowed her to avoid filing a charge of discrimination with the Equal Employment Opportunity Commission (EEOC).
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