Summary
The Maryland Court of Appeals held that a circuit court reviewing contract and tort claims arising from a private hospital's denial of medical staff privileges may not apply the deferential substantial-evidence standard used in administrative-law review. Instead, the court must apply the Maryland summary-judgment standard, granting judgment only when no genuine dispute of material fact exists and the moving party is entitled to judgment as a matter of law. The court therefore reversed the grant of summary judgment for the hospital and related respondents.
Court
Court of Appeals of Maryland
Jurisdiction
Maryland
Decision date
November 26, 2003
Docket number
No. 12, Sept. Term, 2002
Disposition
reversed_and_remanded
Questions Presented
- Whether a private hospital's credentialing decision must be reviewed under the substantial-evidence standard applicable to governmental administrative-agency decisions when the physician asserts contract and tort claims.
- Whether summary judgment on the physician's contract and tort claims was proper under Maryland Rule 2-501(e).
- Whether the hospital bylaws and the business-judgment rule preclude judicial second-guessing of the hospital's medical credentialing decision while permitting litigation of alleged contractual or tortious violations of the bylaws.
- Whether the hospital's bylaws provision stating that the Board's decision was conclusive barred the physician's court action.
Holdings
- A private hospital's credentialing decision is not governmental administrative-agency action and is not subject to judicial review under the substantial-evidence standard when the physician brings common-law contract or tort claims.
- Summary judgment is proper only if the motion and response show that there is no genuine dispute as to any material fact and that the moving party is entitled to judgment as a matter of law; the court may not replace that standard with substantial-evidence review of the hospital record.
- A private hospital may be entitled to summary judgment where it followed valid bylaws and there is no genuine dispute regarding that fact, but the court must apply ordinary summary-judgment principles and may not use substantial-evidence review to adjudicate the hospital's medical judgment.
- The bylaws' statement that the Board of Directors' decision was conclusive did not clearly establish a binding agreement barring the physician from pursuing court action.
Court Document
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