Doctor's discrimination claims dismissed.
In Johnson v. Riverside Health Care System, the Ninth Circuit upheld the dismissal of Johnson’s discrimination claims. The court upheld the dismissal of the 42 U.S.C. § 1981 claim, finding no hostile work environment where there was only one alleged incident of racial discrimination; other incidents, while offensive, were not shown to have arisen from racial animus rather than personal dislike. The state law discrimination claim under California’s Unruh Act, Calf. Civil Code Act § 51, was properly dismissed as the allegation was for employment discrimination, but the statute covered discrimination in the provision of goods and services.
