Unreported / Non-Citable
Background
Life Time suspended Sanjiv Chandan’s gym membership for 90 days after another member reported that Chandan had approached a 17-year-old girl at the pool, sat beside her while shirtless, and spoken with her for approximately eight minutes. Chandan then located the personal Facebook accounts of Life Time manager Walter Gonzales and Gonzales’s wife and messaged both of them about the suspension. Life Time subsequently terminated Chandan’s membership.
Chandan sued for breach of contract, racial discrimination, and public-accommodation discrimination. The district court granted summary judgment to Life Time. On appeal, Chandan argued that genuine disputes of material fact precluded summary judgment and challenged the denial of his motion to compel discovery and related motion to continue.
The Court’s Holding
The Fifth Circuit affirmed. The membership agreement expressly reserved Life Time’s right to terminate Chandan’s membership for any reason, including conduct it considered inappropriate, and Chandan produced no evidence that Life Time breached the agreement. His contract claim therefore failed.
The discrimination claims also failed under the McDonnell Douglas framework. Even assuming Chandan established a prima facie case, Life Time identified his interaction with the minor and his Facebook messages to Gonzales and Gonzales’s wife as independent, nondiscriminatory reasons for termination, and Chandan presented no evidence of pretext. The court did not decide Chandan’s argument that the district court relied on inadmissible hearsay from Life Time’s investigation; because Life Time also submitted video evidence of the pool incident, any error was harmless.
The district court also acted within its discretion in denying the discovery motions. Chandan filed them nearly three months after the discovery deadline and offered no justification for failing to pursue discovery diligently and on time.
Key Takeaways
- A breach-of-contract claim could not proceed when the membership agreement expressly authorized termination for any reason, including conduct the club deemed inappropriate, and the plaintiff supplied no evidence of breach.
- The discrimination claims failed because the plaintiff offered no evidence that Life Time’s stated nondiscriminatory reasons for termination were pretextual.
- The Fifth Circuit declined to decide the hearsay issue because video evidence independently supported Life Time’s stated reason, making any error harmless.
- A district court does not abuse its discretion by denying discovery motions filed months after the deadline when the movant provides no justification for the delay.
Why It Matters
The unpublished decision illustrates the importance of express termination provisions in membership agreements and of evidence showing pretext at the final stage of the McDonnell Douglas analysis. It also underscores that parties seeking additional discovery must act diligently and comply with scheduling deadlines.