Doe v. Mercy Catholic Medical Center

Jane Doe (plaintiff) enrolled in Mercy Catholic Medical Center’s (Mercy) (defendant) diagnostic-radiology residency program (residency program) as a second-year student in 2011. The residency program was accredited by the Accreditation Council for Graduate Medical Education (ACGME) and affiliated with Drexel University’s College of Medicine (Drexel). Doe attended morning lectures by faculty and afternoon case presentations by residents. Doe took mandatory physics classes on Drexel’s campus and sat for annual exams. Dr. James Roe, the director of the residency program, expressed interest in Doe. Doe emailed Dr. Roe and asked him to keep the relationship professional, to which he responded that he wanted to see her during a conference. Doe responded by texting him, and Dr. Roe reported Doe to the human-resources department (HR). After a meeting with HR, Doe was referred to a psychiatrist. In 2012, both Doe and Dr. Roe were getting divorced from their partners and Dr. Roe’s efforts intensified. Doe asked Dr. Roe for a recommendation letter, and Dr. Roe intentionally wrote her a bad recommendation to teach her a lesson. After Doe complained of Dr. Roe’s conduct, Mercy’s vice president met with Doe and then referred her to a psychiatrist. In 2013, Dr. Roe became jealous when Doe became involved with someone else in the office, and he directed another resident to remove Doe’s name as coauthor from a research paper. Doe complained again and was referred to a psychiatrist again. Mercy suspended Doe. On April 20, 2013, Doe was terminated. Doe appealed the decision, and the dismissal was upheld. Doe declined to file another appeal and quit the residency program. Doe sued Mercy, alleging sex discrimination in violation of Title IX. The district court dismissed Doe’s complaint. Doe appealed.