Gallo v. Mayo Clinic Health System-Franciscan Medical Center, Inc.

Gallo was a dermatologist at the Mayo Clinic. Less than a year into her employment, she resigned and entered into a separation agreement to prevent Mayo from saying anything negative about her to prospective employers. Years later, her former supervisor rated her performance as “fair” on two criteria in a credentialing form sent to Mayo after Gallo had been offered a contract to work in New York. That employment offer was rescinded. Gallo sued Mayo for breach of the separation agreement. The Seventh Circuit affirmed summary judgment in favor of Mayo. The separation agreement does not apply to every potential employer but limits itself to a potential employer seeking a reference. Even if the separation agreement did apply to the request, Gallo cannot prove causation. The decision to not hire Gallo was [N]ot based, in any way, on any credentialing decision by any other party; rather, the decision was based upon the combination of Dr. Gallo’s continued efforts to re-negotiate her employment contract, her demand to make changes to the contract that were unacceptable … and the ability to fulfill [the employer’s] staffing needs with a dermatologist who was already providing dermatological services [for the employer]. View "Gallo v. Mayo Clinic Health System-Franciscan Medical Center, Inc." on Justia Law