On April 3, 1995, the Fourth Circuit upheld the right of a Maryland hospital to terminate a surgeon who was HIV-positive (John Doe v. University of Maryland Medical System Corp. (50 F.3d 1261 (4th Cir. 1995)). A resident in the University of Maryland Neurosurgical Training Program was dismissed when hospital administrators learned of his infection with HIV. The resident, known as Dr. Doe, claimed that his termination violated federal laws protecting persons with disabilities. The court upheld the hospital's actions as lawful and affirmed the trial court's grant of summary judgment for the hospital.

Dr. Doe charged that his dismissal from the training program violated the Rehabilitation Act and the Americans with Disabilities Act (ADA).