Unreported / Non-Citable
Background
Sanjiv Chandan approached a 17-year-old girl at a Life Time pool, sat beside her while shirtless, and spoke with her for approximately eight minutes. After another member reported the interaction, Life Time investigated and suspended Chandan’s membership for 90 days.
Chandan then found the personal Facebook accounts of Life Time manager Walter Gonzales and Gonzales’s wife and messaged both about the suspension. Life Time terminated Chandan’s membership. Chandan sued for breach of contract, racial discrimination, and public-accommodation discrimination, but the district court granted summary judgment to Life Time. It also denied his motion to compel discovery and related motion to continue.
The Court’s Holding
The Fifth Circuit affirmed. Chandan produced no evidence that Life Time breached the membership agreement, which expressly reserved the company’s right to terminate his membership for any reason, including conduct it considered inappropriate.
His discrimination claims also failed because, even assuming he established a prima facie case, he offered no evidence that Life Time’s stated reasons for terminating him—his interaction with the minor and his Facebook messages to Gonzales and Gonzales’s wife—were pretexts for racial discrimination. The court also held that any error involving investigative statements was harmless because Life Time presented video evidence of the pool incident.
The district court did not abuse its discretion by denying Chandan’s discovery motions. He filed them nearly three months after the discovery deadline and gave no justification for failing to pursue discovery diligently.
Key Takeaways
- A breach-of-contract claim cannot survive summary judgment without evidence that the defendant violated the agreement’s terms.
- A discrimination plaintiff must produce evidence of pretext after the defendant identifies a legitimate, nondiscriminatory reason for its action.
- A court may deny untimely discovery and continuance requests when the requesting party does not justify its lack of diligence.
Why It Matters
The decision illustrates the importance of express termination provisions in membership agreements and the evidentiary burden plaintiffs face when challenging a business’s stated nondiscriminatory reasons for ending a customer relationship.
It also reinforces that parties must pursue discovery within the scheduling order; filing a motion to compel months after the deadline without an explanation is insufficient to establish an abuse of discretion.