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Halpern v. Wake Forest University Health Sciences

669 F.3d 454 (2012)

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Halpern v. Wake Forest University Health Sciences

United States Court of Appeals for the Fourth Circuit

669 F.3d 454 (2012)

Facts

Ronen Halpern (plaintiff) was a medical student at Wake Forest University Health Sciences (the university) (defendant) from 2004 to 2009. Although Halpern had been diagnosed with Attention Deficit Hyperactivity Disorder (ADHD) during his undergraduate studies and received accommodations, Halpern did not disclose the diagnosis until December 2007, when Halpern requested and received testing accommodations. Halpern failed his first clinical rotation in summer 2006, primarily because of unprofessional conduct: Halpern resisted feedback, had interpersonal difficulties, was absent without permission for more than a week, and failed to use an electronic system so that staff and faculty could provide performance feedback. Halpern was then placed on academic probation. Throughout Halpern’s medical-school studies, academic-computing, student-services, and financial-aid staff members independently complained about Halpern’s abusive, erratic behavior toward staff. Moreover, Halpern continued to have unexcused absences and missed deadlines and failed to complete administrative tasks. Halpern nonetheless successfully completed 10 clinical rotations. Finally, in November 2008, Halpern’s failure to send appreciation letters to scholarship donors after numerous reminders triggered disciplinary proceedings. Halpern submitted letters from a psychiatrist that attributed Halpern’s behavior in part to ADHD. Halpern proposed a special remediation plan that would include therapy and strict probation. Ultimately, the dean of the medical school, Dr. William Applegate, accepted the disciplinary committee’s recommendation to dismiss Halpern. Applegate reasoned that professionalism was a fundamental goal of the medical program. Halpern’s poor treatment of the medical school’s staff indicated that Halpern would disrespect nonphysician healthcare providers, and no accommodation could adequately address Halpern’s professionalism issues. Halpern sued the university in federal district court, alleging that Halpern’s dismissal had violated the Americans with Disabilities Act (ADA) and the Rehabilitation Act (RA). The district court granted the university’s motion for summary judgment, and Halpern appealed.

Rule of Law

Issue

Holding and Reasoning (Floyd, J.)

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