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Illinois district court grants summary judgment to bar resident's defamation claim

The United States District Court for the Northern District of Illinois Eastern Division granted summary judgment to Loyola University Medical Center and Suneel Nagda, MD, in a defamation claim brought by Alexander Chi, MD. Chi worked as a medical resident in the radiation oncology program at Loyola from July 2005 through September 2009, during which time Nagda served as the program director. Chi alleged that throughout his residency he was subjected to false statements ­concerning his conduct by other residents, chief ­residents, program directors, attending physicians, and staff. Chi specifically alleged that Nagda made critical statements about him and his performance based on a personal bias. In 2009, Chi applied for a position at University Medical Center (UMC) in Tucson, Ariz., and as a part of his application, Chi signed a consent form that allowed third parties that had knowledge of his qualifications to release information to UMC. UMC provided Loyola with a copy of the consent form that Chi had signed and requested that Nagda, as the program/training director at Loyola, complete a form evaluating Chi's clinical competence and a form verifying his dates of training. Nagda did not complete the comparative evaluation section of the form but instead wrote "see attached" in the space provided, which was allegedly a reference to Chi's final performance evaluation from Loyola. Nagda checked off the box next to "I cannot ­recommend him/her" on the UMC evaluation form. Chi testified that the credentialing committee at UMC told him that it did not feel comfortable granting him temporary privileges to start working based on Nagda's statement.

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