K. Jeff Carney, M.D., PHARMD v. Emory University

── K. Jeff Carney, M.D., PHARMD v. Emory University ── Court: Court of Appeals for the Eleventh Circuit Date: April 15, 2026 Category: CON USCA11 Case: 24-13070 Document: 40-1 Date Filed: 04/15/2026 Page: 1 of 13 NOT FOR PUBLICATION In the United States Court of Appeals For the Eleventh Circuit ____________________ Nos. 24-13070, 24-13738 Non-Argument Calendar ____________________ K. JEFF CARNEY, M.D., PHARM.D., Plaintiff-Appellant, versus EMORY UNIVERSITY, Defendant-Appellee. ____________________ Appeals from the United States District Court for the Northern District of Georgia D.C. Docket No. 1:21-cv-04531-TWT ____________________ Before JORDAN, ROSENBAUM, and KIDD, Circuit Judges. PER CURIAM: K. Jeff Carney, M.D., Pharm.D., appeals the district court’s grant of summary judgment to his former employer, Emory Uni- USCA11 Case: 24-13070 Document: 40-1 Date Filed: 04/15/2026 Page: 2 of 13 2 Opinion of the Court 24-13070 versity, on his claim that Emory unlawfully required him to un- dergo a “medical examination,” in violation of the Americans with Disabilities Act (“ADA”), see 42 U.S.C. § 12112(d)(4)(A), when it or- dered him to receive leadership coaching following an internal in- vestigation of complaints from medical residents. Because the rec- ord does not support a reasonable inference that the coaching re- quirement included a medical examination or inquiry, we affirm the grant of summary judgment in Emory’s favor. I. Dr. Carney worked for the Department of Urology in Emory’s School of Medicine. He was a urologist at Grady Hospital, where he also served as the site director for the residency program and director of undergraduate medical education. According to Dr. Carney, training residents and fellows was one of his most im- portant job duties. From 2013 through the remainder of his employment, Dr. Carney reported to Dr. Martin Sanda, the chair of Emory Urology. Dr. Carney testified that, during several disagreements with Dr. Sanda between May 2015 and July 2020, Dr. Sanda told Dr. Carney he needed to have his “head examined.” In July 2022, the residency director for Emory Urology sent Dr. Sanda an email about certain concerns she had heard from Grady residents. These concerns were about Dr. Carney and they related to professionalism and respectfulness. Among other con- cerns cited in the email, female residents had complained about Dr. USCA11 Case: 24-13070 Document: 40-1 Date Filed: 04/15/2026 Page: 3 of 13 24-13070 Opinion of the Court 3 Carney touching them and making derogatory jokes about female surgeons. They also said they feared retaliation. The School of Medicine conducted an internal investigation. It interviewed both urology residents and Dr. Carney. Dr. Carney called the residents’ complaints “lies.” He said he would “never” work with the complaining residents again, even if it meant losing his job. 1 The review found that Dr. Carney’s denials and explana- tions “were generally convincing,” but that he failed to appreciate the impact his telling inappropriate jokes had on his reputation. On January 4, 2021, Dr. Sanda emailed Dr