Sadler v. Dimensions Healthcare Corp.
Decision Date | 26 November 2003 |
Docket Number | No. 12,12 |
Citation | 378 Md. 509,836 A.2d 655 |
Parties | Cynthia Denise SADLER v. DIMENSIONS HEALTHCARE CORP., et al. |
Court | Maryland Court of Appeals |
Laurence S. Kaye (The Kaye Law Firm, on brief), Gaithersburg, for petitioner.
Phillip R. Zuber (Sasscer, Clagett & Bucher, on brief), Upper Marlboro, for respondents.
Argued before BELL, C.J., ELDRIDGE,1 RAKER, WILNER, CATHELL, HARRELL, and BATTAGLIA, JJ.
Cynthia Denise Sadler, M.D., petitioner, was denied privileges to admit patients at Prince George's Hospital. Petitioner filed suit against respondents, parties to the denial decision,2 alleging a series of counts, including breach of contract, several torts, and an action for declaratory judgment. The Circuit Court for Prince George's County granted summary judgment in respondents' favor. The Court of Special Appeals affirmed, Sadler v. Dimensions Health, 141 Md.App. 715, 787 A.2d 807 (2001), and we granted Sadler's petition for writ of certiorari. Sadler v. Dimensions Health, 369 Md. 179, 798 A.2d 551 (2002).
In this action, we address the standard by which a circuit court should review, in the context of contract and tort claims, a decision of the Board of Directors of a privately owned hospital as to who should have staff privileges at the hospital. In this case, the trial court granted summary judgment on all counts in favor of respondents on the ground that the hospital's actions, taken in compliance with the hospital's bylaws, were supported by substantial evidence. We shall hold that the trial court, on a motion for summary judgment as to contract and tort claims, may not apply a "substantial evidence" standard akin to that applied during judicial review of the final action of an administrative agency. Rather, in accordance with Maryland Rule 2-501(e), a motion for summary judgment is appropriate only when there is no genuine dispute as to any material fact and the moving party is entitled to judgment as a matter of law. Accordingly, we shall reverse.
Petitioner, a licensed physician in the State of Maryland with a specialty in obstetrics and gynecology (OB/GYN), applied for privileges at Prince George's Health Center. The hospital is owned and operated by Dimensions Health Corporation, a non-profit corporation. The protracted relationship which ensued is described in detail in the opinion of the Court of Special Appeals as follows:
Sadler, 141 Md.App. at 719-722, 787 A.2d at 809-11.
Following the hospital's notification to petitioner of the MEC's decision to terminate her privileges, petitioner appealed, pursuant to the bylaws, to the Ad Hoc Committee.3 Over the following year, the hearing committee convened on nine days, hearing testimony from a variety of witnesses. The witnesses included the individual respondents in the present case, as well as petitioner and a number of additional witnesses called by petitioner. Witnesses provided testimony and presented exhibits. All were subject to cross-examination by counsel for the hospital and petitioner.
On April 1, 1999, the hearing committee issued a thirty-page written report, providing a summation of the evidence presented, its findings with regard to the alleged actions of petitioner, and the appropriateness of the MEC's decision not to extend petitioner's privileges. The committee recommended that the MEC's decision be upheld.
Petitioner exercised her right under the hospital bylaws for appellate review4 by the Board of Directors. Following oral argument, the Appellate Review Committee recommended that the Board affirm the decision of the MEC, and the Board followed that recommendation.
Subsequently, petitioner filed the present action in the Circuit Court for Prince George's County, alleging contract and tort claims. The defendants included the respondents, as well as Johns Hopkins University Hospital, Harold Fox, M.D., and George Huggins, M.D. Respondents filed motions for summary judgment, seeking dismissal for a variety of reasons including immunity under both state and federal law. Following a hearing on respondents' motions for summary judgment,5 petitioner filed a second amended complaint, the subject of the present proceeding. The complaint includes...
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