Background
Sanjiv Chandan approached a 17-year-old girl at a Life Time Fitness pool, sat shirtless in a chair beside her, 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. He sued for breach of contract, racial discrimination, and public-accommodation discrimination. The district court granted summary judgment to Life Time and later denied Chandan’s untimely motion to compel discovery and related motion to continue.
The Court’s Holding
The Fifth Circuit affirmed. Chandan’s breach-of-contract claim failed because he produced no evidence that Life Time breached the membership agreement, which expressly reserved Life Time’s right to terminate his membership for any reason, including conduct it considered inappropriate.
The discrimination claims also failed because Chandan offered no evidence that Life Time’s stated reasons for termination—his interaction with the minor and his Facebook messages to Gonzales and Gonzales’s wife—were pretexts for racial discrimination. Although Chandan challenged statements from Life Time’s investigation as hearsay, Life Time also presented video evidence of the pool incident, making any error harmless. The district court likewise acted within its discretion in denying discovery relief filed nearly three months after the deadline without an explanation showing diligent pursuit of discovery.
Key Takeaways
- A breach-of-contract claim cannot survive summary judgment without evidence that the defendant violated the governing agreement.
- Even assuming a prima facie discrimination case, a plaintiff must produce evidence that the defendant’s legitimate, nondiscriminatory reasons were pretextual.
- A court may deny a motion to compel and related continuance when they are filed months after the discovery deadline and the movant offers no justification for the delay.
Why It Matters
The decision illustrates the difficulty of challenging a private membership termination when the contract grants the business broad termination authority and the plaintiff lacks evidence connecting the decision to race. It also underscores that unsupported allegations of discriminatory motive do not create a genuine factual dispute once the defendant identifies legitimate reasons for its action.
The ruling further emphasizes the importance of pursuing discovery within the court-ordered period. Parties seeking relief after a deadline should be prepared to demonstrate diligence and explain why the requested discovery could not have been obtained earlier.