Mateo-Woodburn v. Fresno Community Hospital

Facts

D is a nonprofit corporation. The medical staff of D is governed by its bylaws, which are formulated by the physicians and thereafter approved by the board of trustees, the governing body of D. The medical staff elects its officers and elects and appoints its committees. Although appointment to membership on the medical staff is made by D, it is based on the recommendation of the medical staff executive committee after review by the credentials committee. A physician must be licensed and qualified, and such qualifications must be reviewed and approved by the medical staff physicians. D cannot appoint physicians to the medical staff unless such physicians comply with all qualifications established in the medical staff bylaws. Under the bylaws, medical staff membership cannot be arbitrarily withheld or terminated without cause. D's department of anesthesiology operated as an open staff. All anesthesiologists were independently competing entrepreneurs with medical staff privileges in anesthesiology. The anesthesiologists were responsible for scheduling themselves for the coverage of regularly scheduled, urgent, and emergency surgeries. The anesthesiologists collectively established a 'rotation' system. Each anesthesiologist was given, on a rotational basis, priority in choosing his or her workload. The system was a disaster. The department chairman was powerless to override the rotation system in order to enforce recommendations about who would be the best choice for the patient. Many 'on-call' anesthesiologists were not qualified to handle a particular emergency and no formal mechanism was in place to ensure that alternative qualified anesthesiologists would become promptly available when needed. The scheduling of anesthesiologists for each surgery case was much more complex than the mere assignment of anesthesiologists to operating rooms. Scheduling also required close cooperation and coordination between nurses, surgeons, and anesthesiologists, often under pressure of urgent and emergency cases. There were delays in scheduling urgent cases because the first call and second call anesthesiologists in charge of such scheduling at times refused to speak to each other. Often, anesthesiologists, without informing the nursing staff, left the hospital or made rounds while one or more of their patients were in post-anesthesia recovery. This situation caused delays as the nurses searched for the missing anesthesiologist. The medical staff made the recommendation that D adopt a closed system. An 'Anesthesia Task Force' was established to study the proposal. It considered four alternative methods of dealing with problems. The committee recommended a director with subcontracted practitioners. The board announced a special open meeting for the purpose of conducting an officially noticed hearing on the recommendation of the medical staff executive committee that the department of anesthesiology be closed. Fifteen physicians made comments at the meeting, including Ps. Four of the six plaintiffs (five on appeal) were in attendance at the meeting. At a meeting of the board of trustees, P presented a counterproposal to the recommended closure of the department. The counterproposal envisioned the appointment of a director of the department and contractual agreements, signed by all existing department members, to abide by the director's established policies and procedures. The board rejected the counterproposal and authorized the formation of a search committee to recruit a director for the department of anesthesiology. The board also determined that upon the appointment of a permanent director, the department would be closed. P accepted the position of interim director on June 13, 1984, and Hass was interviewed for the position on March 7, 1985. The board of trustees hired Hass to be the director of the department of anesthesiology. It was ordered that the department shall be operated as a closed department. Hass had full authority to hire and fire so long as the physician had the proper qualifications. All physicians contracting with Hass were required to qualify as members of the medical staff. Seven of the thirteen anesthesiologists signed the contract. Five Ps refused to sign the contract offered to them. Dr. Woodburn (P), was not offered a contract but testified he would not have signed it, had one been offered. Ps sued D claiming that their medical staff privileges were unlawfully terminated, modified, or curtailed. The trial court found for D and Ps appealed. 

Issues

Rule of Law

Holding and Decision

Legal Analysis

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